STATEMENT OF CONFIDENTIALITY
Following is a description of the confidential information contained in Reliant
Energy HL&P's (“Reliant Energy” or “HL&P”) supplemental ECOM Update filing in SOAH
Docket No. 473-00-1020/PUC Docket No. 22355. The descriptions of confidential information
are categorized by witness. The undersigned attorney has reviewed this information sufficiently
to state in good faith that the information is confidential.
C.J. Mitcham
Figure CJM-2S shows Reliant Energy's forecast of the delivered cost of coal.
Projected coal prices for Reliant Energy's W.A. Parish and Limestone plants are highly valuable
to Reliant Energy's competitors, because they can use these fuel price forecasts to identify an
important component of Reliant Energy's cost to generate electricity. These forecasts can also be
used by competing suppliers to inform their negotiations with Reliant Energy and inflate the
prices for future supplies. Disclosure of this information would cause substantial competitive
harm to Reliant Energy. See TEX. GOV'T CODE §§552.101 and 552.110.
Ms. Mitcham's workpapers to her supplemental direct testimony contain
information including plant heat rates for the W.A. Parish plant, operation and maintenance
expenses and capacity factors.
This information is highly valuable to Reliant Energy's
competitors in the electric generation business, because it provides important data concerning the
operating characteristics and operating expenses of Reliant Energy's generating units. Disclosure
of this information would cause substantial competitive harm to Reliant Energy. See TEX. GOV'T
CODE §§552.101 and 552.110.
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William G. Rice
Schedule VIII-Q-2S contains highly confidential information regarding Reliant
Energy's historical non-fuel O&M, historical taxes (broken out by fuel type), historical capital
investment, historical A&G, and historical fuel expense.
In each of these categories, the
historical information covers the years 1995-1999 and is broken down into further subcategories
such as the generation function, coal/lignite, natural gas, nuclear, and purchased power. The
1999 information is highly valuable to Reliant Energy's competitors in the electric generation
business. Disclosure of this information would cause substantial competitive harm to Reliant
Energy. See TEX. GOV'T CODE §§552.101 and 552.110.
The ECOM model outputs contain highly confidential specific fuel forecasts,
capital forecasts, and purchase power expenses (including, for example, costs associated with
purchased power from the Bayou and Clear Lake cogeneration facilities). This information is
highly valuable to Reliant Energy's competitors in the electric generation business. Disclosure of
this information would cause substantial competitive harm to Reliant Energy. See TEX. GOV'T
CODE §§552.101 and 552.110.
The ECOM model workpapers contain a significant amount of highly confidential
information, which can be grouped generally into the following categories:

Each unit's projected output, which would allow Reliant Energy's competitors to
derive the capacity factor for each of the units.

Projected fuel costs by plant.

Capital expenses and capital additions, which contain forward-looking numbers.

The Production Cost Model (PROSYM) contains information on unit operating
characteristics – such as heat rates, minimum up and down times, outage rates,
and maintenance rates. It also contains fuel forecasts and load forecasts
(including forecasts of interruptible load). Moreover, the hourly load forecasts
generated by this model would allow parties to identify the algorithms used by the
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vendor (Henwood Energy Services, Inc.) in developing this model. Therefore,
this particular set of workpapers is also proprietary to the vendor.

Some of the workpapers also contain unit-specific inputs to the ECOM model,
such as fuel forecasts, heat rate coefficients, start-up costs, and minimum up and
down time. Moreover, some of these workpapers contain a detailed analysis of
outages for a ten year period, which are used to predict forced outage rates.
All of this information is highly valuable to Reliant Energy's competitors in the
electric generation business. This information would allow Reliant Energy's competitors to
quantify some of the most significant costs Reliant Energy incurs in generating electricity.
Disclosure of this information would cause substantial competitive harm to Reliant Energy. See
TEX. GOV'T CODE §§552.101 and 552.110.
Ernie McWilliams
Mr. McWilliams’ workpapers include contracts between HL&P and certain third
party vendors for the provision of environmental retrofit materials and services, along with
invoices and purchase orders associated with the provision of those materials and services.
These contracts, invoices and purchase orders contain highly confidential information. The
terms and conditions established in these contracts (including rates and costs) were the result of
extensive negotiations between HL&P and these vendors. Public disclosure of these contracts,
invoices, and purchase orders would give parties an advantage in negotiating with the vendors
and would therefore cause substantial competitive harm to the vendors. See TEX. GOV'T CODE
§§552.101 and 552.110.
Mr. McWilliams’ workpapers also include documents that contain highly
confidential and sensitive commercial information, such as capital costs. Disclosure of this
information would cause substantial competitive harm to Reliant Energy. See TEX. GOV'T CODE
§§552.101 and 552.110.
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In addition, Figure EWM-2S to Mr. McWilliams’ supplemental direct testimony
identifies key outage dates for HL&P generating units. Mr. McWilliams’ workpapers also
contain back-up material at a more detailed level that Mr. McWilliams used to develop the
outage schedule set forth in Figure EWM-2S.
This information is highly confidential.
Disclosure of this information would cause substantial competitive harm to Reliant Energy. See
TEX. GOV'T CODE §§552.101 and 552.110. If this information were publicly disclosed, it could
impact the price at which HL&P will be able to purchase power on the market. It could also
impact the market price of electricity generally.
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Respectfully submitted,
_______________________________
Gretchen Allen
State Bar No. 00796624
BAKER BOTTS, L.L.P.
910 Louisiana
Houston, Texas 77002
Phone: (713) 229-1323
Fax: (713) 229-1522
ATTORNEY FOR RELIANT ENERGY HL&P
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