I am a power grid reliability engineer at a regional transmission organization, and when I overlaid a generation owner’s day-ahead offers against their own cost-based offer reference and the cold-snap make-whole payments, I realized their vice president of trading was getting paid extra for forcing on units he had quietly bid out.

I am a power grid reliability engineer at a regional transmission organization, and when I overlaid a generation owner’s day-ahead offers against their own cost-based offer reference and the cold-snap make-whole payments, I realized their vice president of trading was getting paid extra for forcing on units he had quietly bid out.

The regional transmission organization operates the wholesale electric market and the bulk transmission system serving roughly four million customers across two states.

I sit on the market operations group at the regional transmission organization control center on the southwest edge of the metropolitan service territory.

My role is senior power grid reliability engineer.

I have held the role for fourteen years.

The generation owner is a vertically separated independent power producer that owns nine thermal units across the regional transmission organization footprint.

The generation owner’s vice president of trading and generation strategy is a man named Hal Cordova.

He has held the position for eleven years.

He is a long-tenured market trader with a lawyer’s hand at the regional transmission organization tariff.

Three weeks earlier I had walked a junior market operations analyst through the minimum-run cost offer mechanics at the bullpen desk on the second floor of the control center.

The junior analyst was a man named Augusten Brodbeck on his fourth month of certification rotation.

I sat at the bullpen desk with a printed minimum-run offer curve from the regional transmission organization market software interface on a manila folder.

I pulled a printed unit commitment optimization log alongside the offer curve.

I told Augusten the minimum-run cost offer is the dollar-per-megawatt-hour floor below which a thermal unit’s owner says the unit cannot economically run.

I told him the market software reads the minimum-run cost offer alongside the unit’s start-up cost offer and the unit’s incremental energy offer when the software solves the day-ahead unit commitment.

I told him the unit commitment optimization is what selects which thermal units will be online to serve the next operating day’s forecasted load.

I told him a unit with a high minimum-run cost offer is more likely to be committed off if cheaper alternatives exist.

I told him a unit committed off in the day-ahead market can still be forced on later by the regional transmission organization operator in real time when the reserve margin tightens.

I told him a unit forced on by the regional transmission organization operator can receive a make-whole uplift payment under the regional transmission organization tariff to cover the gap between its bid and its actual operating cost.

I told him the make-whole uplift payment exists because the regional transmission organization needs the unit and the regional transmission organization tariff cannot strand the unit’s owner with operating losses.

I told him a generation owner who bids a unit out of day-ahead unit commitment with an elevated minimum-run cost offer and then collects a make-whole uplift when the unit is forced on in real time is using the tariff in a way the tariff did not intend.

Augusten wrote that down.

He asked me whether the regional transmission organization tariff prohibited the conduct.

I told him the conduct is technically inside the market software’s tolerance for the minimum-run cost offer.

I told him the conduct is outside the Federal Energy Regulatory Commission tariff’s prohibition on physical withholding.

I told him the two facts are not the same fact.

I told him a regional transmission organization market monitoring unit reads the audit trail.

Two weeks earlier I had sat at my desk in the bullpen reading the Federal Energy Regulatory Commission anti-manipulation rule under eighteen Code of Federal Regulations Part one c and the Federal Power Act Section two twenty-two civil-penalty authority.

I had read the Commission’s two thousand eighteen enforcement matter against a midwest generation owner who had bid units into a polar vortex day-ahead market with elevated minimum-run cost offers and collected make-whole uplift payments when the units were forced on in real time.

I had read the consent order.

I had read the disgorgement schedule.

I had read the individual responsibility paragraph naming the firm’s vice president of trading and generation strategy.

I had clipped a printed copy of the consent order to the inside cover of a manila folder labeled Cold-Snap Reserve Margin Reference in pencil.

Six months earlier I had sat at a stakeholder dinner in the lobby restaurant of the regional transmission organization conference hotel.

Hal Cordova walked over to my table with a bottle of red wine and two empty glasses.

He poured a glass for me without asking.

He set the glass in front of me.

He poured a glass for himself.

He said competitive markets reward operational excellence.

He smiled.

He said the firm’s nine thermal units were the regional transmission organization’s winter readiness.

He said the regional transmission organization market monitoring unit was a paperwork shop and not a real check on a real trader.

He said the firm’s market lawyers had been reading the tariff since the regional transmission organization stood up the day-ahead market sixteen years earlier.

He raised his glass of red wine.

I raised my glass of water.

He walked back to a table of generation owner traders and laughed at something one of them said.

This began on a Monday morning when the regional transmission organization meteorology desk pushed the cold-snap forecast revision for the coming week.

The cold-snap forecast revision raised the system-wide peak load forecast for the worst day of the snap by nine percent.

I pulled the cold-snap day-ahead unit commitment optimization scenarios that the regional transmission organization market software had run overnight against the revised forecast.

I pulled the regional transmission organization market software’s unit-level offer data for the generation owner’s nine thermal units.

I pulled the generation owner’s cost-based offer reference filings on file with the regional transmission organization under the tariff cost-based offer rules.

Two of the generation owner’s nine thermal units showed minimum-run cost offers in the day-ahead market sixty-three percent and seventy-one percent above the cost-based offer reference on file under the tariff.

The two thermal units were bid out of the day-ahead unit commitment.

The two thermal units would be in the next-day reserve margin calculation as off-line capacity.

The wall clock in the bullpen above the regional transmission organization market software console read ten hundred.

Ten hundred was the regional transmission organization day-ahead market clearing time.

Ten hundred had been the day-ahead market clearing time under the tariff for sixteen years.

An offer is a story a generator tells the market software.

The cost reference is a story they filed under Federal Energy Regulatory Commission oath.

The audit trail is a story the market system writes itself.

Three of them must agree if the conduct is honest.

My name is Jenny Bui.

I am a power grid reliability engineer.

Hal Cordova thought minimum-run offers were a trader’s tool, but he forgot the audit trail keeps its own time.

The first backstory scene was at my desk in the bullpen Monday afternoon at thirteen hundred.

I pulled the regional transmission organization market operations data warehouse with my read-only senior reliability engineer credentials.

I queried unit-level day-ahead offer data for the generation owner’s nine thermal units over the past one hundred eighty operating days.

I queried the regional transmission organization cost-based offer reference data on file with the regional transmission organization for the same nine thermal units over the same one hundred eighty operating days.

I queried the regional transmission organization real-time unit commitment dispatch logs for the same nine thermal units over the same window.

I queried the regional transmission organization make-whole uplift payment ledger for the same nine thermal units over the same window.

I built a cross-joined spreadsheet on the bullpen workstation with one row per operating-day per unit.

Each row carried the unit identifier, the day-ahead minimum-run cost offer, the cost-based offer reference, the offer-versus-reference ratio, the day-ahead unit commitment status, the real-time forced-on status, the make-whole uplift payment for the operating day, and the regional transmission organization operating-day reserve margin.

The cross-joined spreadsheet covered one thousand six hundred twenty rows.

Forty-seven rows showed the same pattern.

Each of the forty-seven rows carried an offer-versus-reference ratio above one point three, a day-ahead unit commitment status of bid out, a real-time forced-on status of forced on, a make-whole uplift payment, and an operating-day reserve margin below the regional transmission organization tariff’s reserve-margin trigger.

Forty-one of the forty-seven rows belonged to the same two thermal units the cold-snap forecast scenarios had flagged.

The second backstory scene was Tuesday morning at oh-eight-thirty at the regional transmission organization cost-based offer reference filings archive.

The cost-based offer reference filings archive is a read-only repository the regional transmission organization tariff requires generation owners to keep current.

The cost-based offer reference filings on file for the two thermal units listed minimum-run cost references thirty-eight dollars and forty-two dollars per megawatt-hour.

The cost-based offer reference filings carried the firm’s vice president of trading and generation strategy signature on the certification page.

The cost-based offer reference filings were on file under the firm’s Federal Energy Regulatory Commission oath.

The day-ahead minimum-run cost offers in the forty-seven flagged rows averaged sixty-two dollars and seventy-three dollars per megawatt-hour respectively on the two thermal units.

The offer-versus-reference ratios averaged one point sixty-three and one point seventy-four.

I printed each of the two cost-based offer reference filings.

I printed each of the forty-seven flagged day-ahead minimum-run cost offers.

I printed the cross-joined spreadsheet.

I clipped each printout to the inside cover of the manila folder labeled Cold-Snap Reserve Margin Reference in pencil.

The third backstory scene was Tuesday afternoon at fourteen hundred at the regional transmission organization market monitoring unit lead’s office on the third floor of the control center.

The regional transmission organization market monitoring unit lead was a woman named Mahalia Stuckenschneider.

She had held the regional transmission organization market monitoring unit lead role for seven years.

I sat at her conference table.

I laid out the two cost-based offer reference filings, the forty-seven flagged day-ahead minimum-run cost offer printouts, the cross-joined spreadsheet, the make-whole uplift payment ledger excerpts, and the regional transmission organization real-time forced-on dispatch logs.

She read each printout in order.

She set them down on the table.

She told me the regional transmission organization market monitoring unit had been seeing the pattern on other generation owners’ offers during the past year and had been considering a formal market-power referral.

She told me the cold-snap forecast revision moved the analysis from quarterly to immediate.

She told me the regional transmission organization market monitoring unit would draft a formal market-power referral to the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations under eighteen Code of Federal Regulations Part one c.

She told me she would copy the regional transmission organization chief compliance officer.

She told me she would expect a parallel written notice to the affected state public utility commission market staff.

She told me the regional transmission organization market monitoring unit would not formally invoke the tariff’s market-power mitigation provision without the regional transmission organization chief compliance officer’s countersignature.

I told her I would draft the parallel state public utility commission notices.

I told her I would draft the parallel Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice in the senior reliability engineer voice rather than the regional transmission organization market monitoring unit voice.

She nodded.

The fourth backstory scene was at the kitchen table at my house Tuesday evening at twenty hundred.

I pulled up the Federal Energy Regulatory Commission anti-manipulation rule under eighteen Code of Federal Regulations Part one c on the laptop.

I read the rule.

I pulled up the Federal Energy Regulatory Commission published enforcement guidance on minimum-run cost offer manipulation and make-whole uplift patterns.

I read the guidance.

I pulled up the two thousand eighteen consent order from the midwest polar vortex case.

I read the consent order.

I drafted the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice at the kitchen table.

I drafted the parallel state public utility commission notices for the two affected states.

I drafted a cover memorandum naming the conduct as a regional transmission organization tariff minimum-run cost offer pattern divergent from cost-based offer reference filings on file under Federal Energy Regulatory Commission oath, accompanied by a make-whole uplift payment cluster on the same units when the units were forced on by the regional transmission organization operator in real time.

I closed the laptop.

I placed the printed Federal Energy Regulatory Commission anti-manipulation rule, the printed enforcement guidance, the printed consent order, the drafted notices, and the cover memorandum into a sealed envelope.

The fifth backstory scene was at my desk in the bullpen Wednesday morning at oh-seven-thirty.

I picked up the desk phone.

I called the regional transmission organization market monitoring unit lead.

I confirmed the formal market-power referral was on Mahalia Stuckenschneider’s draft queue.

I confirmed the parallel notices to Federal Energy Regulatory Commission Office of Enforcement Division of Investigations and to the affected state public utility commissions would be transmitted by the close of business Wednesday.

I hung up the desk phone.

Ten hundred Friday was the queued day-ahead market clearing time for the worst day of the cold snap forecast.

Ten hundred Friday was the moment the cold-snap day-ahead market would clear under the tariff.

Once it clears with the withheld offers the inflated uplift payment pattern settles into the official regional transmission organization market record for that operating day.

The hour stops being a clearing ritual.

The hour becomes the moment another operating day’s worth of market harm is recorded into a settlement that has to be unwound through Federal Energy Regulatory Commission enforcement.

I did not call Hal Cordova.

Hal Cordova’s internal logic was on his end of the wire and not mine.

He believed the conduct was on the right side of the regional transmission organization tariff because it was technically inside the market software’s tolerance.

He believed a regional transmission organization reliability engineer could not move faster than the firm’s market lawyers.

He believed the regional transmission organization market monitoring unit was a paperwork shop.

He did not know about the forty-seven flagged rows in the cross-joined spreadsheet.

He did not know about the regional transmission organization market monitoring unit lead conference table Tuesday afternoon at fourteen hundred.

He did not know about the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice I had drafted at the kitchen table Tuesday evening.

Wednesday at sixteen forty-two a regional transmission organization market operations scheduling notice came through to the bullpen broadcast queue.

The scheduling notice was issued by the regional transmission organization market operations group manager.

The scheduling notice accelerated the cold-snap day-ahead market clearing for the worst day of the snap by one operating cycle.

The accelerated day-ahead market clearing was scheduled for ten hundred Thursday morning instead of ten hundred Friday morning.

The accelerated clearing was justified in the scheduling notice by the cold-snap forecast severity and by transmission-constrained pocket congestion projections.

I forwarded the scheduling notice to Mahalia Stuckenschneider at sixteen forty-eight.

I forwarded the scheduling notice to the regional transmission organization chief compliance officer at sixteen forty-nine.

I forwarded the scheduling notice to the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations intake desk at sixteen-fifty.

Mahalia Stuckenschneider called me back at sixteen fifty-six.

She told me she would brief the regional transmission organization chief compliance officer that evening on the formal market-power referral.

She told me she would brief the regional transmission organization chief executive officer through the chief compliance officer that evening on the tariff’s market-power mitigation provision.

She told me the regional transmission organization market subcommittee public stakeholder meeting was scheduled for oh-nine-thirty Thursday morning.

She told me Hal Cordova was scheduled to present the generation owner’s winter readiness at the public stakeholder meeting at oh-nine-thirty Thursday morning.

She told me Federal Energy Regulatory Commission Office of Enforcement staff, regional transmission organization market monitoring unit staff, and state public utility commission market staff were already confirmed in the public stakeholder meeting audience.

I hung up the desk phone.

The regional transmission organization chief compliance officer was a man named Reginald Pflueger.

He had held the chief compliance officer role for nine years.

He called me at seventeen forty-three.

He told me he had read the formal market-power referral draft.

He told me he would countersign the formal market-power referral by oh-seven-hundred Thursday morning.

He told me he would invoke the tariff’s market-power mitigation provision before ten hundred Thursday morning if Mahalia Stuckenschneider transmitted the formal market-power referral by the same hour.

He told me he expected me at the regional transmission organization market subcommittee public stakeholder meeting at oh-nine-thirty Thursday morning.

He told me he expected me to be a co-signatory on the regional transmission organization market monitoring unit market-power referral acknowledgment.

I hung up the desk phone.

That evening at eighteen hundred I watched a streamed clip of Hal Cordova speaking on a regional electric industry winter readiness press call.

The press call was hosted by a regional electric industry trade association.

The press call audience included state energy reporters, generation owner peer firms, and the regional transmission organization media affairs office.

Hal Cordova spoke for eleven minutes.

He told the audience the firm’s nine thermal units were second to none in winter readiness.

He told the audience the firm’s bidding behavior was disciplined and compliant with the regional transmission organization tariff.

He told the audience the regional transmission organization market monitoring unit kept all market participants honest and the firm welcomed market-monitoring scrutiny.

He smiled at the camera.

He joked that the firm’s traders ran on hot coffee and reliable forecast data.

He concluded with a one-line remark about the cold-snap day-ahead market clearing the next morning with the firm’s units ready to serve the region.

He stepped off the press call.

I closed the streamed clip.

That evening I read the regional transmission organization market subcommittee public stakeholder meeting agenda.

Hal Cordova was scheduled to present the generation owner’s winter readiness as the first item on the agenda at oh-nine-thirty.

The regional transmission organization market monitoring unit’s quarterly market-power surveillance report was scheduled as the second item on the agenda at oh-nine-fifty.

I drafted a one-page reliability engineer briefing on the cross-joined spreadsheet for the regional transmission organization market subcommittee public stakeholder meeting.

I copied the regional transmission organization chief compliance officer.

I copied the regional transmission organization market monitoring unit lead.

I closed the laptop.

I placed the one-page briefing, the formal market-power referral acknowledgment co-signature line, the sealed envelope from Tuesday evening, the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice acknowledgment that had come in by email Tuesday at twenty-three hundred, and the two state public utility commission notice acknowledgments that had come in by email Wednesday at oh-nine-thirty into a sealed file pouch.

I labeled the file pouch in pencil with Market Subcommittee Thursday Oh-Nine-Thirty.

I locked the file pouch in the bullpen lockbox under the bullpen workstation.

I set the lockbox security lockout pin to my reliability engineer identification number.

I walked out of the regional transmission organization control center through the south parking-lot side door at nineteen forty-one.

I drove home with a duplicate set of the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice acknowledgment, the state public utility commission notice acknowledgments, the printed Federal Energy Regulatory Commission anti-manipulation rule, the printed enforcement guidance, the printed consent order, and the cover memorandum in the inside pocket of my coat.

The wall clock above my front entry read twenty fifty-four when I walked through the front door.

I read the regional transmission organization tariff market-power mitigation provision once at the kitchen table.

I read the regional transmission organization market monitoring unit market-power referral procedural framework twice.

I read Hal Cordova’s two thousand twenty-three winter-readiness keynote remarks from the regional transmission organization annual market summit twice for tone.

I closed the file pouch.

I placed the file pouch on the kitchen table beside the kitchen lamp.

The kitchen lamp threw a soft round pool of light on the file pouch and on the kitchen table.

Ten hundred Thursday was twelve hours away.

Ten hundred Thursday was the queued cold-snap day-ahead market clearing time under the accelerated regional transmission organization scheduling notice.

Ten hundred Thursday was the hour the cold-snap day-ahead market would clear with the withheld offers if the regional transmission organization market monitoring unit and the regional transmission organization chief compliance officer did not invoke the tariff’s market-power mitigation provision before the clearing solver finalized the day-ahead unit commitment.

The regional transmission organization market subcommittee public stakeholder meeting was scheduled for oh-nine-thirty Thursday morning.

Oh-nine-thirty Thursday morning was ten and one-half hours away.

I closed the kitchen lamp.

I walked to the front entry.

I locked the front entry deadbolt.

I climbed the stairs.

I set the alarm for oh-five-thirty.

I did not sleep until after midnight.

Thursday morning at oh-nine-thirty I walked into the regional transmission organization market subcommittee public stakeholder meeting room on the fifth floor of the regional transmission organization control center.

The regional transmission organization market subcommittee chair was a woman named Calandra Yarbrough.

She sat at the chair’s seat at the head of the U-shaped table.

Eight other market subcommittee members sat around the U-shaped table.

Reginald Pflueger sat in the regional transmission organization chief compliance officer chair to the chair’s right.

Mahalia Stuckenschneider sat in the regional transmission organization market monitoring unit lead chair to the chair’s left.

I sat in the regional transmission organization senior reliability engineer chair beside the regional transmission organization market monitoring unit lead chair.

Two Federal Energy Regulatory Commission Office of Enforcement Division of Investigations staff attorneys sat in the audience in the second row.

Three regional transmission organization market monitoring unit analysts sat in the audience in the third row.

Two state public utility commission market staff representatives sat in the audience in the fourth row.

Hal Cordova walked in at oh-nine-thirty-one with a firm winter readiness binder under his right arm and a printed slide deck in his left hand.

He sat at the stage table at the front of the meeting room.

The wall clock above the chair’s seat read oh-nine-thirty-two.

Calandra Yarbrough called the meeting to order at oh-nine-thirty-three.

She recognized Hal Cordova first.

Hal Cordova projected his winter readiness slide deck on the meeting room screen.

He stood at the stage table.

He spoke for seven minutes.

He told the audience the firm’s nine thermal units were second to none in winter readiness.

He told the audience the firm’s day-ahead offers were inside the market software’s tolerance for the minimum-run cost offer.

He told the audience the firm followed the regional transmission organization tariff in every operating day.

He told the audience the regional transmission organization market monitoring unit kept all market participants honest and the firm welcomed market-monitoring scrutiny.

He smiled at the audience.

He concluded with a one-line remark about the cold-snap day-ahead market clearing in twenty-eight minutes with the firm’s units ready to serve the region.

He sat down at the stage table.

He folded his hands on top of the firm winter readiness binder.

Calandra Yarbrough recognized me next.

I opened the sealed file pouch on the U-shaped table.

I laid out the cross-joined spreadsheet excerpt.

I laid out the two cost-based offer reference filings.

I laid out the forty-seven flagged day-ahead minimum-run cost offer printouts.

I laid out the regional transmission organization make-whole uplift payment ledger excerpt for the same units.

I laid out the regional transmission organization market monitoring unit formal market-power referral cover page.

I laid out the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations notice acknowledgment.

I laid out the two state public utility commission notice acknowledgments.

“The regional transmission organization market monitoring unit has transmitted a formal market-power referral to the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations under eighteen Code of Federal Regulations Part one c at oh-seven-eleven this morning,” I said.

“The regional transmission organization chief compliance officer countersigned the formal market-power referral at oh-seven-oh-three this morning.”

“The cross-joined spreadsheet shows forty-seven operating days over the past one hundred eighty operating days on which the firm’s two thermal units were bid out of day-ahead unit commitment with minimum-run cost offers above one point three of the cost-based offer reference on file under the firm’s Federal Energy Regulatory Commission oath.”

“The make-whole uplift payment ledger shows make-whole uplift payments on the same two thermal units when the units were forced on in real time during the same operating days.”

“The audit trail of bid changes in the regional transmission organization market software shows the bid changes were entered during the cold-snap forecast update windows over the past two weeks.”

“The video the firm projected this morning shows the firm’s day-ahead offers are inside the market software’s tolerance.”

“Tolerance is not the same as cost-based reference, Hal.”

“The audit trail shows when the offers diverged.”

Hal stood up at the stage table.

“Make-whole uplift is what the tariff pays,” he said.

“Make-whole uplift exists to keep generators whole when the regional transmission organization needs the units.”

“Our firm is providing winter readiness.”

“Our offers are inside the market software’s tolerance.”

“We follow tariff.”

I looked at the regional transmission organization make-whole uplift payment ledger excerpt on the U-shaped table.

“Make-whole uplift is what the tariff pays a generator that did not lock its own units out of commitment with offers above cost-based reference, Hal,” I said.

“The two thermal units were bid out of day-ahead unit commitment on forty-seven operating days with offers above one point three of cost-based reference.”

“The two thermal units were forced on in real time on the same forty-seven operating days.”

“The make-whole uplift payments on the same forty-seven operating days totaled the figure on the regional transmission organization market monitoring unit referral cover page.”

“An offer is a story, Hal.”

“The cost-based reference is on file under your firm’s Federal Energy Regulatory Commission oath.”

“The audit trail is on the regional transmission organization market system.”

“The regional transmission organization market monitoring unit has all three.”

The Federal Energy Regulatory Commission Office of Enforcement attorney in the second row of the audience quietly lifted a notebook to her knee and uncapped a pen.

A state public utility commission commissioner staff representative in the fourth row of the audience set a printed packet flat on his desk.

A regional transmission organization market monitoring unit analyst in the third row of the audience wrote one line on a yellow legal pad and underlined it twice.

Calandra Yarbrough recognized Reginald Pflueger.

Reginald Pflueger told the chair the regional transmission organization had invoked the tariff’s market-power mitigation provision on the affected units’ day-ahead offers effective oh-nine-fifty-five.

He told the chair the cold-snap day-ahead market clearing solver would proceed at ten hundred with the mitigated offers in place of the firm’s submitted offers for the two affected units.

He told the chair the regional transmission organization market monitoring unit had formally transmitted the market-power referral to the Federal Energy Regulatory Commission Office of Enforcement Division of Investigations at oh-seven-eleven this morning.

He told the chair the regional transmission organization chief compliance officer had countersigned the referral at oh-seven-oh-three.

He told the chair the regional transmission organization Bureau of Reliability would update the cold-snap reserve margin calculation with the mitigated unit commitment.

Calandra Yarbrough called for a recess of the regional transmission organization market subcommittee public stakeholder meeting at oh-nine-fifty-seven.

Hal Cordova closed the firm winter readiness binder.

He stood up at the stage table.

He told the chair he would refer further questions to the firm’s outside counsel.

He walked off the stage table.

He walked out the side door of the meeting room at oh-nine-fifty-nine.

The firm retained outside Federal Energy Regulatory Commission practice counsel within the day.

The wall clock above the chair’s seat reached ten hundred.

The cold-snap day-ahead market clearing solver finished at ten-oh-three with the mitigated offers in place of the firm’s submitted offers on the two affected units.

The clearing summary published on the regional transmission organization market software interface at ten-oh-four.

The Federal Energy Regulatory Commission Office of Enforcement Division of Investigations opened a non-public investigation file at ten-oh-seven.

Three years after the regional transmission organization market subcommittee public stakeholder meeting I was at the senior reliability engineer console in the regional transmission organization control room on the second floor of the control center.

The control room ran on cool light-emitting diode lighting on a wall of monitors.

The hum of the cooling units came up through the floor.

The smell of new keyboard plastic was faint on the console keyboard the regional transmission organization information technology group had replaced last week.

The cold-snap event window during which I had filed the formal market-power referral had landed two specific transmission-constrained pockets on rolling outages of forty-five minutes each.

The rolling outages were initiated by the regional transmission organization operator under the tariff’s emergency operating procedure on the second night of the cold snap.

A retired teacher in a senior-housing complex on the south end of one of the two transmission-constrained pockets had called nine one one during the rolling outage.

The retired teacher’s oxygen concentrator had stopped when the power dropped.

The retired teacher had been transferred by paramedics to the regional hospital under emergency medical service protocol.

She survived.

She was discharged from the regional hospital two days later.

She moved out of the senior-housing complex inside the month.

Her grandson stood up at the next regional transmission organization market subcommittee public stakeholder meeting six weeks after the cold snap.

He told the regional transmission organization market subcommittee his grandmother had survived the rolling outage.

He told the regional transmission organization market subcommittee his family was moving his grandmother to a senior-housing complex in a different state with a different regional transmission organization.

He told the regional transmission organization market subcommittee his family did not know whether the new regional transmission organization had the same minimum-run cost offer surveillance posture.

He sat down at the public comment microphone.

I did not change the move.

I attended the public comment session in the regional transmission organization market subcommittee meeting room.

I logged the grandson’s name and the senior-housing complex address in pencil on a printed regional transmission organization reliability engineer’s outreach log.

I did not approach the grandson at the end of the session.

The Federal Energy Regulatory Commission Office of Enforcement Division of Investigations issued a Notice of Alleged Violation on the firm and on Hal Cordova in his individual capacity at one hundred forty-eight days from the formal market-power referral.

The Notice of Alleged Violation cited eighteen Code of Federal Regulations Part one c and Federal Power Act Section two twenty-two.

The matter settled three years later.

The settlement included civil penalties on the firm of fourteen million dollars.

The settlement included disgorgement of make-whole uplift payments to the regional transmission organization market settlement reserve of nine million two hundred thousand dollars.

The settlement included an individual responsibility consent on Hal Cordova naming the conduct and a five-year ban on serving as an officer of a market participant inside Federal Energy Regulatory Commission jurisdiction.

The firm retained its winter readiness portfolio of nine thermal units.

The firm replaced its vice president of trading and generation strategy in the same operating quarter.

The regional transmission organization market monitoring unit updated its market-power surveillance posture to flag offer-versus-cost-reference ratios above one point two on minimum-run cost offers during forecasted reserve-margin-trigger days.

The wall clock above my reliability engineer console read oh-nine-fifty-nine.

The day-ahead market clearing solver was running on the regional transmission organization market software.

The clearing solver completed at ten hundred.

The day-ahead market cleared on the standing operating-day schedule.

The clearing summary published on the regional transmission organization market software interface at ten-oh-three.

The clearing summary carried no flagged offer-versus-cost-reference patterns on the firm’s two affected thermal units.

I do not feel triumph at ten hundred.

I feel the difference between an hour I fought to keep inside the tariff and an hour I get to close on my own signature.

I signed the daily reliability engineer’s log on the console in pencil at ten-oh-four.

I dated the log entry.

I logged the regional transmission organization operating-day reference number.

I logged the regional transmission organization market monitoring unit market-power surveillance acknowledgment number.

I closed the log gently.

I walked across the room.

I refilled my coffee from the carafe on the side cabinet.

The cooling units hummed.

The wall of monitors carried the regional transmission organization grid topology, the cold-snap reserve margin projection for the coming week, and the cold-snap day-ahead unit commitment status on the firm’s nine thermal units.

The two thermal units that had been bid out for forty-seven operating days were online in the unit commitment status pane.

The smell of new keyboard plastic was faint on the console keyboard.

Hal thought tolerance was the same as truth.

He forgot the audit trail had been keeping its own time.