Comments on Discussion paper 3

1. Please provide a summary of your organization’s feedback on the Discussion Paper posted October 4, 2023:

Our comments mainly focus on the CCDEBE process and suggestions to improve it. 

2. Provide your organization’s feedback on the revision tracking and action items in the discussion paper, and include any outstanding topics that are not captured by the discussion paper:

No comments

3. Provide your organization’s feedback on the Proposed Problem Statements section of the discussion paper, and include any outstanding problem statements that are not captured by those proposed in the discussion paper:

Our comments mainly address probelm statements 3 through 6 and the CCDEBE process in general.

There have been numerous comments during the working group meetings that the CCDEBE process is overly burdensome, too time consuming and does not necessarily achieve desired results.  The following are some of the challenges and issues scheduling coordinators face with CCDEBE bids:

1. When to use manual vs automated reference level change requests
2. Tight deadlines (sometimes gas has not traded yet by 8:00 am)
3. Automated reference level change requests require a lot of unnecessary detail
4. Threshold caps are too low
5. Units already committed in the day ahead market, either economic or RUC, which negates the ability to change the start-up costs or minimum load costs in real-time

The automated reference level change request process is somewhat perplexing in that it requires the SC to replicate and submit default commitment costs and default energy bids using the new gas price, yet the gas price used to calculate the bids is not required to be submitted.  In turn, the CAISO has to reverse engineer the bids to derive the gas price used to calculate the submitted bids.  Yet the purpose of the automated reference level change request process is to get approval to use a higher gas price.

A much more efficient process would be to allow the SC to simply submit the desired gas price and the CAISO could either approve the gas price followed by calculating new adjusted default commitment costs and default energy bids or deny the request.  If the gas price is approved, then it would eliminate the need for thresholds and the cost recovery process beyond the threshold amount. 

The above recomendations would comply with the principles of the working group (efficiency, simplicity, transparency and feasibility.)

4. Provide your organization’s suggestions for metrics or methods to measure the impact of problem statements proposed in this section:

No comments

5. Provide your organization’s suggestions for what principles and potential trade-offs to consider in association with problem statements in this section:

No Comments

6. Additional comments:

1. Please provide a summary of your organization’s feedback on the Discussion Paper posted October 4, 2023:

PacifiCorp appreciates the opportunity to comment on the discussion paper. In general, PacifiCorp finds the discussion paper useful for summarizing the discussions that have taken place during the working group so far. PacifiCorp provides comments on the following:

• The topic ‘Market participants do not have sufficient information to make gas procurement decisions.’
• The topic ‘Gas burn limitations as a market input.’
• Suggestion of a new problem statement
• Use of Slido polling during working group meetings as a method to determine the impact of the problem statements.
• Potential trade-off with the currently proposed problem statements.
• Process improvements for future working group meetings.

2. Provide your organization’s feedback on the revision tracking and action items in the discussion paper, and include any outstanding topics that are not captured by the discussion paper:

PacifiCorp seeks more discussion on the topic ‘Market participants do not have sufficient information to make gas procurement decisions’, and has the following questions or comments from past working group discussions:

• Is the two-day ahead advisory schedule intended to be utilized for the WEIM or the EDAM?
• In PacifiCorp’s view, a longer advisory schedule, ideally seven days ahead, is needed to help scheduling coordinators procure the right amount of gas and to alleviate challenges associated with the misalignment of the gas and power trading days.
• The usefulness of any day ahead advisory schedule is highly dependent on the accuracy of the schedule. Can the CAISO perform an analysis to show how accurate an advisory schedule would be using the input the CAISO already receives from market participants? A better understanding of the accuracy will give stakeholders more information to discuss how advisory schedules could be improved for future use.

PacifiCorp also seeks more discussion on the details within the topic ‘Gas burn limitations as a market input’, and has the following questions and comments:

• The discussion paper states the need for participants to reflect gas burn limitations on a given pipeline, but PacifiCorp would like to see more discussion on using gas burn limits as a resource constraint. PacifiCorp believes that the market may have the potential to dispatch gas resources more efficiently if the optimization utilized a resource’s daily gas burn as a constraint. Operational flow orders (OFOs) can also affect a resource’s ability to burn gas, so PacifiCorp would like to further explore how OFOs could be used by the market optimization to dispatch gas resources more efficiently.
• The CAISO cites a manipulation concern as the reason why discussions shifted to the ability for the ISO to treat limitations as an input formed by the gas company. Can the CAISO please expand on what the manipulation concern is in the next discussion paper iteration?

3. Provide your organization’s feedback on the Proposed Problem Statements section of the discussion paper, and include any outstanding problem statements that are not captured by those proposed in the discussion paper:

 PacifiCorp generally agrees with the Proposed Problem Statements section of the discussion paper and offers an additional proposed problem statement for consideration by stakeholders:

• Gas burn limitations are not reflected in the market for WEIM resources, which may lead to less than optimal dispatch of gas resources across the day.

4. Provide your organization’s suggestions for metrics or methods to measure the impact of problem statements proposed in this section:

Since the problem statements likely impact WEIM entities differently, PacifiCorp suggests that the CAISO conduct an in-meeting Slido poll to see which problem statements are most impactful to stakeholders. Each problem statement, assuming it is relevant to one or more entities, is worth discussing in the GRM initiative. However, it may be best to first find solutions to problem statements that have a broad impact across the market.

5. Provide your organization’s suggestions for what principles and potential trade-offs to consider in association with problem statements in this section:

 PacifiCorp sees the following trade-offs with some of the problem statements:

• Improvement in market optimization vs feasibility due to market clearing times.
• Increase in data made available to stakeholder vs accuracy of that data.
• Improvement of procedures and processes vs time and effort needed to make the improvements.

6. Additional comments:

PacifiCorp requests that more than one week be given to stakeholders to submit comments. Stakeholders are currently participating in multiple CAISO initiatives plus numerous initiatives outside of the CAISO. In order to provide meaningful input in the stakeholder process, PacifiCorp requests at least two weeks minimum is given for stakeholders to submit comments.  Additionally, PacifiCorp requests that all deadlines be posted on the CAISO calendar to assist stakeholders in staying informed about meetings and comment submission deadlines.  Lastly, to avoid potential confusion, PacifiCorp requests the CAISO limit their use of ‘tentative’ meetings and that the CAISO choose a consistent cadence for meetings and comment submissions for the working groups currently ongoing.