Jerret Fischer (email@example.com)
Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to comment on the Short-Long Start Unit Definitions Update initiative. In general, SRP supports simplifying and aligning definitions for resources in both the Tariff and Business Practice Manuals (BPMs). Correcting misalignments that currently exist between the Tariff and BPMs will provide market participants clear rules of engagement. To better understand whether the proposed changes will impact SRP’s operations, we are requesting clarification on several items in the Issue Paper:
SRP supports the CAISO’s Joint Authority decisional classification on the basis that both the EIM and the day-ahead market will be impacted by the outcome of this initiative. As CAISO staff noted at the January 26, 2022, initiative webinar, amending the Short Start and Long Start definitions will impact and align the definitions in the EIM and day ahead market.
SRP supports the proposed tariff definition changes but requests one clarification. For Section 34.6, the Tariff language states, “Once per hour, near the top of each Trading Hour, immediately after the FMM and the RTUC for the same interval is completed the CAISO performs an approximately five (5) hour Short-Term Unit Commitment (STUC) run using SCUC and the CAISO Forecast of CAISO Demand over a 270-minute time horizon to commit Medium Start Units and Short Start Units, with Start-Up Times greater than the time period covered by the RTUC described in Section 34.3.” SRP requests that CAISO address whether the term “Start-Up Times” should be changed to “Cycle Times” to reflect the time that is considered for commitment decisions.
SRP appreciates the CAISO’s consideration of these comments.
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