Comments on Working group 8

1. Please provide a summary of your organization’s comments on the GRM WG 8 discussion:

NV Energy supports the CAISO’s proposal to kick off the stakeholder initiative to begin working towards solutions for the problem statements developed during the working group phase.  The initiative should develop sufficient tools to aid EIM and potential EDAM participating Entities in managing gas constraints. CAISO should conduct a stakeholder initiative in 2024 to resolve the problem statements identified in the working group.

2. Provide your organization’s comments on the ISO’s plan for transitioning to policy development for this initiative:

The gas management working group has developed 11 problem statements that encompass the major issues that have been identified with a participant’s ability to manage gas nominations while participating in the CAISO wholesale market. The market initiative scope should cover all identified problem statements and encompass all areas that impact gas management. For instance, this initiative’s scope should cover market bidding methodology, market mitigation, market timelines, and any necessary analysis or reporting that is identified as a solution. The gas management issues have been ongoing for the Desert Southwest region in the EIM, therefore, these issues need resolution for the EIM as well as for participants that are considering the possibility of joining the Day Ahead Market.

3. Provide your organization’s comments on the WG 7 survey results and action items:

NV Energy generally supports the feedback or comments that CAISO received regarding the working group 7 meeting that were summarized in the working group 8 meeting.

4. Provide your organization’s comments on the assessment of problem statements 1-2:

NV Energy supports the problem statements 1 and 2 that have been developed in the working group and is eager to begin the stakeholder phase to resolve these high priority issue statements.

5. Provide your organization’s comments on the ISO’s recommendations for policy development and next steps:

To reiterate, NV Energy supports CAISO’s recommendation to develop an updated gas management issue paper based on the discussions from the working group meetings in order to begin the next phase to develop solutions for the identified gas management issues.

6. Additional comments:

1. Please provide a summary of your organization’s comments on the GRM WG 8 discussion:

PacifiCorp appreciates the time and effort devoted to this working group from stakeholders and the CAISO. The working group process has allowed for open discussion on the challenges stakeholders are facing related to gas resource management. PacifiCorp believes the process has led to problem statements that are reflective of challenges described by stakeholders. PacifiCorp supports the decision to transition the working group to the policy discussion phase.

2. Provide your organization’s comments on the ISO’s plan for transitioning to policy development for this initiative:

PacifiCorp is supportive of the CAISO’s plan for transitioning to the policy development phase of this initiative. PacifiCorp’s takeaway from the working group 8 meeting was that stakeholders were not opposed to any of the problem statements, which signals to PacifiCorp that the stakeholder community can begin to discuss solutions.

3. Provide your organization’s comments on the WG 7 survey results and action items:

PacifiCorp agrees with many of the survey responses from stakeholders, particularly the comments around wanting a discussion on gas resource management during the winter storm in January 2024 and an ISO interpretation of the data being presented. PacifiCorp believes a working group meeting specifically on gas resource management during the January 2024 winter storm would be informative because many of the challenges stakeholders have expressed in past working group meetings likely happened during the storm. For example, stakeholders were managing impacts due to procuring gas for a holiday weekend when gas prices were volatile. Perspectives from the CAISO and stakeholders on the challenges they faced will give the working group a good starting place to begin discussions on potential solutions.  

4. Provide your organization’s comments on the assessment of problem statements 1-2:

For problem statement 1, PacifiCorp appreciated the background on the Aliso Canyon gas-electric coordination policy as it helped create an understanding of policy decisions the CAISO has made in the past to increase the information available to stakeholders to make gas procurement decisions. PacifiCorp also found the discussion around the potential effectiveness of a D+2 advisory schedule with the bids the CAISO currently receives useful and believes it might be a good place for the working group to focus its attention on when solutions to problem statement 1 are discussed further.

For problem statement 2, PacifiCorp believes the working group should discuss gas procurement challenges during the January 2024 winter storm in a future meeting because it is a recent experience that can be used to better understand the impact of any potential solutions. The event may have also highlighted challenges related to other problem statements as well that will be worth considering in a working group meeting.

5. Provide your organization’s comments on the ISO’s recommendations for policy development and next steps:

PacifiCorp requests an alteration to problem statement 8 for the discussion paper. The problem statement is currently worded to imply that the stakeholders only have challenges related to gas burn limitations issued by gas companies. In PacifiCorp’s opinion, this problem statement should be broadened by omitting the words ‘issued by gas companies’ in the problem statement. By broadening the problem statement, the working group can think through solutions for all situations when gas burn limitations could be communicated to the market.  

As for the next steps, PacifiCorp is supportive of CAISO’s direction. PacifiCorp believes the discussion paper will give the working group a common place to begin discussing solutions to the problem statements.

6. Additional comments:

1. Please provide a summary of your organization’s comments on the GRM WG 8 discussion:

Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to submit comments regarding the scope of the gas resource management working group. SRP values CAISO’s efforts and is supportive of transitioning to policy development. SRP is particularly interested in the CAISO incorporating stakeholder feedback into the formulation of the issue paper and straw proposal. This collaborative approach will be important for developing effective policies that address challenges of gas resource management.

2. Provide your organization’s comments on the ISO’s plan for transitioning to policy development for this initiative:

SRP acknowledges the CAISO’s plan for transitioning to policy development in the gas resource management initiative. SRP appreciates the structured approach in developing an issue paper and the utilization of stakeholder feedback. SRP also values the CAISO’s commitment to a collaborative process for shaping a straw proposal. SRP requests that CAISO address and provide clarity on the prioritization and timing of this initiative in relation to the EDAM go-live. SRP would like clarity on the amount of progress that is to be expected before EDAM is operational and how this initiative will coordinate with the EDAM business practice manual (BPM) process.  Further SRP encourages the CAISO to clearly define the scope of this initiative with respect to how it plans to address and possibly include efforts related to the alignment between the gas and power markets.

3. Provide your organization’s comments on the WG 7 survey results and action items:

SRP appreciates the CAISO’s efforts to address stakeholder feedback from the WG 7 survey. SRP is generally supportive of the action items outlined in response to the survey, which include analysis of the ‘Cold Snap’ event data, and review of the manual reference level adjustment process. Further, SRP is encouraged by CAISO’s intention to ensure that data and analysis aligns with market participants actual experiences to enhance relevance and applicability.

4. Provide your organization’s comments on the assessment of problem statements 1-2:

SRP appreciates CAISO’s assessment of problem statements (PS) 1-2. SRP has reviewed the PS and recommends the following revision to address challenges more specifically:

PS1: The reliance on illiquid gas cycles due to day-ahead schedule misalignments increases operational risks and costs, exacerbated by the D+2 advisory's lack of reliability. Addressing these issues is essential for enabling informed procurement decisions, improving market efficiency, and ensuring stability.

PS2: Real-time market unpredictability, intensified by the rise of variable energy resources (VERs), poses challenges in cost recovery, gas supply procurement, risking grid and gas pipeline reliability. Developing responsive market tools to accurately forecast and manage these dynamics is crucial for maintaining operational efficiency and market stability.

5. Provide your organization’s comments on the ISO’s recommendations for policy development and next steps:

SRP supports CAISO’s recommendations for policy development. However, SRP is concerned with the timeline in the next steps that provides stakeholders nine calendar days to review and submit comments on the discussion paper. SRP suggests the CAISO extend the comment period to at least 10 business days to provide various parties within stakeholder organizations time to review and consolidate comments to better inform the policy development.

6. Additional comments:

No additional comments at this time.