Comments on Working group 6

Gas resource management working group

Comment period
Dec 08, 11:30 am - Dec 15, 05:00 pm
Submitting organizations
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California ISO - Department of Market Monitoring
Submitted 12/18/2023, 02:42 pm


Aprille Girardot (

1. Provide your organization's feedback on the Gas Resource Management working group session 6 discussion:

Please see the linked comments from the Department of Market Monitoring.

Salt River Project
Submitted 12/15/2023, 10:47 am


Jerret Fischer (

1. Provide your organization's feedback on the Gas Resource Management working group session 6 discussion:

The Salt River Project Agricultural Improvement & Power District (SRP) appreciates the opportunity to comment on the recent Gas Resource Management Working Group and the CAISO's efforts to address problem statements (PS) 6, 7, 9, and 10.

As it relates to PS6, SRP believes the current requirement for one resource per submission in the reference level change request process is cumbersome. Allowing a single submission to cover multiple resources and configurations (for multi-stage generators) at the fuel zone would greatly enhance efficiency and operational flexibility for Scheduling Coordinators.

For PS7, SRP agrees with extending the deadline for manual Reference Level Change Request submissions, recognizing the alignment challenges with the actual gas day timing. Additionally, SRP notes that the current process does not effectively account for the full range of Hours Ending (HE) 1-24 for gas units. This limitation impacts SRP's ability to accurately reflect the price dynamics of the gas day, particularly for the early hours (HE1-8), when tomorrow's gas day price is not available early enough for effective adjustments.

In regard to PS9, the inability to dynamically reflect costs from different fuel hubs limits operational flexibility and cost accuracy. A fuel hub price approach, reflective of the marginal cost, with an option to adjust start-up costs and minimum load costs values, would more accurately reflect the actual cost incurred.

Lastly regarding PS10, SRP agrees with CAISO's proposed solution to allow resources to reflect accurate cost in a timely fashion. This approach to dynamically and accurately adjust costs when switching between different fuel types, such as gas and diesel, is a positive step. It ensures fair and efficient market operations by accurately reflecting the actual cost of generation, aligning with operational realities.

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