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Extract to table / analysis-of-preliminary-findings.docx
analysis-of-preliminary-findings.docx
Parties
Dunmore Energy Holdings Ltd
Dunmore Power Trading LLC
Dunmore Midstream Partners LP
Harkness LLP
Whitfield Economic Advisors LLC
Ridgeway Compliance Solutions LLC
Crestline Document Solutions LLC
Dates
October 5, 2023
October 2, 2023
October 10, 2023
January 3, 2022
March 17, 2023
April 3, 2023
May 22, 2023
May 24, 2023
May 30, 2023
June 5, 2023
Amounts
$30.8
$18
$12.8
$250,000
$15
$47.3
$614
$2.1
$3.82
$891
Obligations
The burden to explain why a market participant would offer generation at deeply negative prices is a practical reality that Dunmore must overcome
These weaknesses must be factored into the settlement calculus and addressed proactively in the Response to Preliminary Findings
FERC precedent recognizes that disgorgement serves a remedial purpose, and the Commission has stated that disgorgement amounts must be based on a reasonable and supportable estimate of the unjust profits actually derived from the manipulative conduct
Beyond this level, the escalation risk of proceeding to an Order to Show Cause and ALJ hearing must be seriously weighed against the financial and reputational costs of litigation