Brief 3

Jeff Merola submitted testimony before the Federal Energy Regulatory Commission (FERC) on behalf of the California Attorney General and the California State Public Utilities Commission. His testimony addressed the question of whether certain energy transactions conducted by market participants outside of California were part of trading strategies, as described in the infamous “Enron memos,” designed to manipulate the California power markets. In particular, he analyzed energy transactions between Portland General, a Northwest utility, and Enron, to determine whether these were part of circular trading strategies employed by Enron to collect congestion payments from the California ISO, without relieving congestion in real time. Mr. Merola also testified regarding the remedies that should be considered where transactions may have violated standards in the Federal Power Act or the California ISO Tariff.