Reporting out-of-market transactions

Based on a discussion I had with Tim, we should report out-of-market
transactions with the FERC and should not question the ISO about their
reporting out-of-market transactions for the following reasons:

Even though the Commission's order referred only to bids into the ISO, it was
not artfully written. Otherwise FERC would not get any reporting information
necessary for refunds.
We have always said that out-of-market should be more transparent and more
liquid. As long as this information is withheld from the market, these goals
will not be achieved.
Nor will the Commission's goal of moving volumes out of the spot market be
achieved if parties can simply withhold from the spot market and sell
out-of-market without FERC scrutiny.