Reliant Energy Power Generation, Inc. et al. 
Summary of Response and Counterclaim
by SDG&E and PG&E
filed July 30, 1999

Case No. 7119829599

		Reliant Energy’s claim to be paid for ancillary service capacity provided under Reliability Must Run (“RMR”) rate schedules should be denied because the CAISO Tariff does not authorize such payments. Because owners of RMR units are paid for such service under RMR rate schedules, even if the Tariff allowed such payments this would result in improper double recovery. Because the Tariff does not authorize payments for RMR ancillary service capacity, SDG&E and PG&E claim that CAISO should refund to Scheduling Coordinators substantial amounts improperly billed and previously paid by load-serving Market Participants.