DERTF: DERa Participation Model (IR070) (20210412)

Consumers Energy appreciates the opportunity to provide comments on this topic.

Consumers Energy continues to believe that MISO’s proposal to start with Distributed Intermittent Resource (DIR) and Energy Storage Resources (ESR) based models for DERa participation is the appropriate approach.  As stated by many in the stakeholder community, an initial DIR/ESR focus is likely the easiest to implement, least cost, permits a wide breadth of capabilities and allows additional time for software development and participation.

MISO is recommending that small resources (those DERas less than 1 MW in size) must self-commit.  Consumers Energy believes that this is an appropriate approach, particularly given the potentially complex, costly and time-consuming investments that would be required to the optimization engine to enable economic commitment of resources of this size.

The Organization of MISO States’ Distributed Energy Resources Working Group (OMS DERWG) appreciates the opportunity to submit the following comments. This feedback does not represent the position of the OMS Board of Directors.

The OMS DER WG is not at this time aware of gaps in the ESR or DIR models for energy or ancillary services, however, as the OMS DER WG has noted in previous comments, we agree that use of the ESR and DIR market participation models are useful starting points, however, they must be evaluated in light of the capabilities of DERas. The conversation on use of these models is just beginning, and there has been little input from DER-Aggregators (DERAs) on this subject. OMS DER WG would like to see more robust discussion on each of the components of these market participation options and discussions with DERAs to ensure that we are fulfilling the FERC Order to accommodate DERa attributes to the extent possible. It would be useful to hear from DERAs on this subject and including an analysis of the merits of other DERA- or RTO proposals. Notably, it is the OMS DERWG’s understanding that uses of these proposals are intended for energy and ancillary market products only and that discussions regarding capacity requirements should occur soon.

Regarding self-commitment of resources under 1MW, it seems like this may be a sufficient short-term solution as we work how to incorporate early DERas, however, longer term, as DERas increase in numbers and complexity, MISO (and all stakeholders) should ensure a pathway is established to revisit the existing approach as warranted. The OMS DERWG supports retaining flexibility in what is created today, to ensure adaptability and modification as needed in the future.

Lastly, the OMS DER WG found MISO’s filing to FERC seeking an extension for Order 841 illustrative in what MISO is representing can be accommodated for ESRs with MISO’s existing software versus what is capable with the new Market System Enhancement (MSE) software. The OMS DER WG would like MISO to provide the same reasoning and overview regarding DERA and DERas and the existing software versus the MSE to the DER TF.

MPPA generally supports WPPI Energy's feedback.

Thanks,

David Sapper

dsapper@ces-ltd.com

Xcel Energy appreciates the opportunity to provide feedback regarding the DERa participation model and self-commitment.

As we have stated before, Xcel Energy believes that using the ESR and DIR participation models a reasonable approach as leveraging these existing market participation models allows DER aggregations less than 1 MW to participate in the market in the near future without significant market system upgrades.  In addition, we have no concerns regarding the proposal that DERas<1 MW must be self-committed as this balances the need to open the market to smaller DERas with the current capabilities of the optimization engine.

Voltus is concerned by MISO’s proposed reliance on the Energy Storage Resource (ESR) asset type, given that implementation of ESR is delayed until 2025. DIR is not a suitable interim path to market, as DIRs cannot participate in the Spinning Reserve or Supplemental Reserve markets. 

The Demand Response Resource Type 1 and 2 (DRR1 and DRR2) products could be a better fit for DER aggregations. DRRs can: 

• participate in energy and ancillary services, 

• aggregate across EP nodes, 

• self-commit or offer in at a price, 

• and accommodate on/off resources (type 1) or resources that can respond to setpoint instructions (type 2). 

A new M&V method to handle energy injection would need to be added to the rules governing DRRs, and the minimum aggregation size would need to be reduced to 0.1 MW, but otherwise DRR is preferable to ESR and DIR. 

The proposed participation model does not pay sufficient attention to capacity, and to the ability of DERAs to provide emergency capacity. The LMR and EDR programs, which are currently limited to demand response, should be amended to allow aggregation of heterogeneous DERs. As with DRRs, the only necessary change would be the introduction of M&V that could measure energy injection instead of or in addition to net load reduction. 

Opening up existing, proven asset classes to new technologies is a faster, easier way to implement Order 2222 than using ESR, which is years away from actual implementation. DRRs, LMRs, and EDR already function in MISO’s dispatching algorithms and have established rules for registration, telemetry and aggregation that could function for DERs as well as they have for demand response.

Emily Orvis

____________________

Senior Energy Markets Manager

Voltus, Inc.

(703) 785-8269

To understand what a DERa participation model must achieve, MISO should articulate the needs for a multitude of potential DERa use cases. While the Environmental Sector appreciates MISO’s efforts to provide DER aggregation examples as a way of understanding the pros and cons of proposed participant models, the examples provided in the April 12, 2021 are insufficient for determining the right participation model. MISO should work with stakeholders to identify the multiple use cases of various combinations of DERs that are likely to be aggregated and articulate participation models that serve those various uses. 

MISO’s proposed reliance on the DIR and ESR participation models is insufficient for many DER resource types. MISO is attempting to fit the square peg of DERa into the round hole of previously developed participation models. While this may have been understandable when MISO had to make a compliance filing on FERC Order 2222 in July 2021, FERC granting of a 9-month compliance extension means that MISO has time to be more thoughtful about what kind of new participation models can and should be developed to get the most out of DER. We believe that MISO needs to develop a new DERa-specific participation model to comply with FERC Order 2222. Shoehorning resources into old participation models does not comply with FERC’s stated goal to “remove barriers to the participation of distributed energy resource aggregations in the capacity, energy, and ancillary service markets”.

The DIR was originally designed for wind resources and later expanded to solar resources. As MISO has noted, the DIR does not allow for small resources and would need to be expanded to include 0.1 MW resources. Because the DIR was designed for utility scale intermittent resources, it has forecasting requirements that are not suitable for DER aggregations. We are concerned that these forecasting requirements will be a significant barrier to DER aggregations and will keep many valuable resources out of the market. Further, DIR is not suitable for participation in ancillary services markets. This means that DERa that include intermittent resources would not be able to readily participate in ancillary services markets even if they could overcome the forecasting requirements.

While the ESR would allow participation in the ancillary services market, the status of the ESR is highly uncertain given MISO’s recent request of FERC to postpone ESR implementation to at least 2025. This means that DERa will have to wait more than three years beyond FERC Order 2222 compliance to use the ESR. While this may not prevent timely compliance with the order, it will severely delay implementation. In other words, otherwise eligible DERa will need to wait years for completion of the ESR before being able to effectively participate in the MISO markets. This delay is especially problematic considering the insufficiency of DIR as a participation model.

The Environmental Sector remains concerned about the self-scheduling requirements of the proposed participation models. We support AEMA’s proposal that resources are required to self-schedule only if they do not pas the Net Benefits Test. Requiring all DERs <1 MW to self-schedule under DIR may create significant logistical hurdles for these small resources. It may keep some of these small but valuable resources from participating in the markets.

WPPI’s responses to the two questions posed in this DERTF feedback request (due 4/26) are as follows:

• Distributed Energy Resource aggregation capabilities not captured under variable energy (Dispatchable Intermittent Resource) or flexible (Energy Storage Resource) DERa resource types
  • WPPI has limited experience with DERs. We are not aware of DERa capabilities or functionality not captured in the proposed participation models.

• Commitment of small resources
  • It seems reasonable that both of MISO’s proposed DERa participation models will not provide for MISO commitment of a small DERa. In the case of the proposed ESR DERa participation model, the ESR participation model on which it is based does not provide for MISO commitment of any size ESR. And, in the case of the proposed DIR DERa participation model, the DIR participation model on which it is based currently does not provide for MISO commitment of less than 1 MW. In other words, the commitment of small resources in the proposed DERa participation models is consistent with the underlying models on which they are based.

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (DERTF) on the proposed participation models for DER that were presented at the April 12, 2021 meeting of the DERTF. AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.

            AEMA offers the following feedback on the issues raised by MISO.

• Capabilities or functionality not covered by ESR and DIR functional models.

MISO has proposed to force DER aggregations into existing MISO participation modes for DIRs and ESRs at the 0.1 MW level. AEMA remains concerned about this approach because this proposal does not capture the robust attributes of an aggregated set of DER resources. Specifically, AEMA suggests that MISO create a model that allows both the reduction of on-site load and the injection of electricity into the grid for a single participation model. MISO has suggested that the ESR participation model would allow for the resource to both inject and withdraw energy; however, this model is not the same as the actual characteristics of a robust aggregation of heterogenous DER assets without significant modifications to the extent that MISO should simply create a new model. For example, a DER Aggregation with on-site generation, storage, and demand response. Common ESR parameters like managing state of charge and charging energy do not make sense for many combinations of heterogenous DER aggregations. AEMA requests that MISO presents more details on how these characteristics would be captured in a modified ESR model and converted to market participation if MISO is going to pursue a modified ESR model.

      AEMA also requests clarification as to whether an aggregation of DER could participate in other MISO models (like DRR I, DRR II, or GEN), if the aggregation was over the current size restrictions of 1 MW. It appears MISO is proposing to only reduce limits for DIRs and ESRs down to 0.1 MW, but it does not state if a DERA could register as an alternative resource type at a higher level, like 1 MW. AEMA proposes that in the absence of a new participation model, MISO should allow DER Aggregators to register their assets within any of the current MISO Market Participation models, particularly DRRs.

      Additionally, AEMA does not believe that limiting aggregations over 1 MW for any participation of aggregations of DERs meets the intent of Order 2222 which specifically calls for minimum size participation of 0.1 MW, particularly since MISO has not demonstrated that that DRR resources under 1 MW meet the requirements of “technical infeasibility.” MISO may recall that the minimum size requirements and the opportunity to aggregate DRR across multiple nodes remains an outstanding barrier to participation that was identified in MISO’s compliance filing for Order 719.   

• Commitment for small resources.

MISO has suggested that small aggregations of DERs (less than 1 MW) would be required to self-commit. AEMA recognizes the challenges of economically clearing small resources within the Energy and Ancillary Services Market and does not object to the necessity of requiring small aggregations (less than 1 MW) to self-commit into the MISO market. 

AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed in the DERTF. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to meet with AEMA members.

Respectfully Submitted, 

Katherine Hamilton

Executive Director, Advanced Energy Management Alliance

Katherine@aem-alliance.org

202-524-8832

or

DeWayne Todd

DDT LLC

dewaynetodd1297@gmail.com

812-573-8052

MGE can support the recommendations:  

(1) How would existing resource types have to be changed to represent the range of DER aggregation's characteristics? DIRs and ESRs at 0.1 MW for DER.

(2) How should Market Systems address small resource size in optimization engines? Small (<1 MW) DERas must self-commit.

Both recommendations address the practical ability to manage the many potential small DERs that may want to participate in MISO's markets.