DERTF: Evaluate Framework (IR070) (20210201)

DTE appreciates this opportunity to provide feedback on MISO’s evaluation framework.  DTE is happy to discuss and/or clarify this feedback either through stakeholder forums or through other discussions with MISO. 

Overall feedback on MISO’s approach

During the coordination framework discussion at the 2/1 DER Task Force meeting, MISO stated that the existing Tariff provisions related to Aggregators of Retail Customers (“ARCs”) provide a foundation for consideration of DERA registration and related processes and requirements.  DTE disagrees with this statement. 

During its tariff update in Docket No. ER20-2591, MISO stated that it will “likely make additional substantive Tariff filing(s) in the future to improve MISO’s ability to register ARCs and to facilitate their participation in MISO’s markets.”  MISO’s statement implies that further improvements are still needed.  In that docket, numerous affected stakeholders also raised concerns about the robustness of MISO’s processes for handling ARCs and the challenges in working through the existing processes.  MISO listed some of these concerns in its presentation materials for the 2/1 DER Task Force meeting. 

Before using the current ARC processes as a foundation for DERA-related efforts, MISO should identify a path to addressing the concerns raised by stakeholders.  Addressing these issues will likely be a less complex undertaking than the DERA coordination framework and could provide MISO with the opportunity to implement a more limited scope test-run before layering on the additional complexities associated with DER aggregation.   

Feedback on evaluation questions (slide 8-9)

In addition to the questions that MISO has posed within each category on slide 8 and 9, DTE proposes additional questions that should be included in the evaluation framework as well as provides some comments on the questions MISO has already listed:

Market Design

• New questions
  • How should DERA capacity be accredited?  How will that capacity value be validated/tested?
  • What should be the maximum size of a resource participating in an aggregation?  What should be the maximum size of an aggregation?
  • Clarifications
    • How will work on hybrid resources impact or be impacted by the Order 2222 work?

Qualification, Registration, and Modeling

• New questions
  • What are the roles and responsibilities for the Electric Distribution Company, Distributed Energy Resource Aggregator, Relevant Electric Retail Regulatory Authority, and MISO in the registration process?
  • What information does a DERA provide as part of its registration, and to which parties does it provide that information (e.g., distribution operators may need circuit location information for resources participating in an aggregation)?
  • What information does a DERA provide to allow modeling and interconnection studies, and to which parties does it provide that information?
  • If a DERA is a market participant but not an asset owner, how can will MISO ensure that DERAs have control over the resources?
  • Clarifications
    • With regard to updating distribution factors, will distribution factors have to be a parameter of a DERA’s offer to the market?  It seems that distribution factors may be far from static if the capabilities of the underlying resources are constantly changing, so changes to a DERA’s offered distribution factors should flow through the day-ahead and real-time markets. 
    • Along these lines, who will calculate, validate and approve the distribution factors? How often are distribution factors updated? How will the calculation of distribution factors account for changing resource and grid conditions?

Data Requirements and Communications

• New questions
  • What processes will enable distribution operators to capture distribution system impacts in both the DA and RT timeframe?  What type of modeling interface needs to take place between the transmission system and the distribution system?  The distribution operator may need to run a parallel DA clearing to ensure no impacts the distribution system.  There may need to be a similar process for the RT market. 
  • What process will allow the distribution company to override MISO’s dispatch?
  • Clarifications
    • The coordination on DER aggregation needs to happen among all parties.  Thus, MISO’s question on coordination should be rephrased to state “how should MISO, RERRAs, distribution companies, and DERAs coordinate DER aggregation”
    • With regard to situational awareness, MISO should clarify that its evaluation needs to consider situational awareness of both transmission operators and distribution operators
    • Can MISO explain what it means by “supplement bidding parameters with forecasted values”?

Feedback on the draft evaluation framework (slide 10)

With respect to the draft evaluation framework, DTE believes that the existing evaluation categories are appropriate.  However, there should be prioritization among the evaluation categories.  For example, DTE proposes that the “requirements of the order” and “grid reliability and resiliency” have a higher priority than market efficiency, solution complexity, and implementation costs.  The former two evaluation categories are mandatory and should not be compromised. The latter three are more of negotiable criteria that can be compared and traded off.

DTE also recommends a few clarifications to these evaluation categories.  Specifically, DTE recommends expanding “grid reliability and resiliency” to “grid safety, reliability and resiliency”.  DTE also recommends that MISO clarify its category on implementation costs to indicate that this will consider total costs for all parties to implement, including costs to MISO, EDCs, RERRAs, and DERAs.

The Entergy Operating Companies ("EOCs")^[1] appreciate and support MISO’s efforts in developing the needed framework to help identify and define important design elements and options for Order 2222 compliance. 

In response to MISO’s formal feedback request made during the February 1, 2021 DERTF meeting, the EOCs will be submitting a detailed response to MISO’s questions via an email to Stakeholder Relations today. 

The EOCs appreciate the opportunity to provide input. 

The Environmental Sector is generally supportive of the MISO’s evaluation framework. We encourage MISO to move with urgency toward the substance of compliance.

The broad array of technologies that can be classified as DERs means that MISO should expect new and/or improved technologies to enter the markets in the future. We propose that MISO include in “Market Efficiency” a description that considers the ability for a solution to adapt to new and/or improved technologies going forward.

MISO should also include in “Market Efficiency” a description that evaluates the ability of a solution to value and compensate resources for all the benefits a resource is technically capable of providing.

MISO should include a description of the “Implementation Costs” that considers life cycle costs, including the risk that a solution will be outdated in the near future due to changes in markets, technologies, etc. For example, a solution with low initial implementation costs may be more expensive in the long run than more robust solutions with higher upfront costs if the cheaper solution is more likely to be outdated in a few years.

Sincerely,

The Environmental Sector

The Organization of MISO States’ Distributed Energy Resources Working Group (OMS DERWG) appreciates the opportunity to submit the following comments in response to MISO’s feedback request regarding the FERC Order 2222 Evaluation Framework and Question Set.  This feedback does not represent the position of the OMS Board of Directors.

 Evaluation Framework

OMS DERWG finds the proposed evaluation framework to be a useful starting point and framing for analysis. The gap analysis and the ‘yes/no’ assessment of existing market products and their capabilities in relation to Order 2222 requirements presented at the February 5^th DER TF is be helpful in the first cut of the work that needs to be conducted. OMS DER WG believes it is crucial that the DER TF begin working immediately on the issues associated with each item as laid out in the work calendar for several reasons.

First, due to the short timeframe, each DER TF meetings will need to be clear in advance about what questions will be asked and answered and MISO will need to provide stakeholders with sufficient time to review the material.

Second, it is likely that issues for evaluation in each of the topic meetings will have the potential to be circular or may inform other meeting date topics or potentially change the preferred trajectory (impacting previous meeting topics).

Third, due to the short timeframe (extension or not) and the likelihood that not all issues will be able to be resolved, is it important that in each meeting that issues are triaged, without stakeholder input, on which are near term needs and which can be dealt with long-term in a post-compliance filing.

With only four months remaining to the compliance deadline, either multiple stakeholder-based straw proposal should be put forth for evaluation for each meeting and subject area, or a more detailed work plan and clear set of materials for stakeholders to comment on should be released by MISO for each meeting.

Evaluation Questions

As to the Evaluation Questions, the OMS DERWG find the set of questions to be a reasonable start for evaluation. Evaluation questions set cannot possibly be complete or perfect at the onset, and questions and considerations will develop as the discussion proceeds. It is more important that we start work versus getting the questions perfected.

OMS DER WG is interested in not only using the questions for evaluation purposes but also to prompt and further stakeholder discussion in the DER TF meetings and to see if the final product and considerations in MISO’s compliance filing address these initial questions.

OMS DERWG recommends that both the original and additional question sets be applied for evaluation. Both provide different considerations that are reasonable for assessment. Further, it is crucial that definitions of the market product and service that is being sold are clear as states will use these definitions and product attributes to some degree to delineate retail and wholesale services. It is assumed that states will bear the brunt of this delineation by resolving any misalignment between the MISO tariff and state-jurisdictional retail tariffs. For instance, states will likely need to ensure their interconnection rulesets and retail tariffs specify the services being provided, which will ultimately be used to prevent the duplication of services (offering the same service at wholesale and retail - energy, capacity, and ancillary services) and relatedly, financial double counting in settlements. State regulators will likely be called upon to resolve any disputes that arise from any of the above, in addition to the processes already embedded in MISO’s tariffs.

Additionally, OMS DERWG supports the continued use of the issues tracking tab on the MISO spreadsheet. There are issues and questions that arise that are broader than 2222 (but exacerbated by Order 2222) that need action by MISO and stakeholders. The tracking tool that has been created will be useful for all stakeholders.

OMS DERWG appreciates the opportunity to provide refinement and additions – and recommends adding the following questions:

Market Design:

1. What is different about DERAs versus DRR1 or DRR2 (or other product types) that may require different multi-nodal geographic aggregation considerations?
2. How can multi-node aggregation be accommodated at different scales (utility boundaries, zonal crossings, LBAs, etc.)? What nodal-scope attributes should be considered? What are the pros/cons to each?
3. Are there baseline zonal considerations that will be required for data collection or sharing, regardless of any potential aggregation nodal-scope (i.e. forecasting requirements) and therefore should be used to inform potential geographic boundaries? If so, what and why?
4. MISO Proposed Question: “How will pseudo-tied assets be considered?”
   1. Need clarity on this question. Is it assumed that there may be DERAs in, say, PJM, that are participating in MISO markets? Does pseudo-tied in this question/context have the same meaning as other psuedo-ties in MISO, or is this an analogous concept?
   2. Are there considerations that need to be made about internal or potential external aggregations to the MISO footprint? (depending on the definition used within this conversation, I.e. “external aggregations”)
5. How may the proposals impact utilities that oscillate over the four million MWh threshold?
6. Does the solution need additional considerations for utilities or distribution companies that are nested under other distribution companies or multiple companies?

 Planning and Interconnection

1. Do solutions and coordination frameworks, or contracts, include all the parties that may be affected? Are there any considerations that should be applied for unintended effects and costs?

 Qualification, Registration, and Modeling

1. What level of information and data transfer needs to be automated for optimal functionality, versus what has to be – or could be, conducted manually?
2. What is the delineation between functionalities of implementation pre-Market System Enhancement versus after? What are the cost trade-offs and likely time difference in implementation?

 Data Requirements and Communications

1. What is the full scope of cost of any solution to the full electrical system, are those costs reasonable to each entity, and were they fairly prioritized?
2. What risk to distribution system and distribution forecasting entity is there if forecasted distribution/DERA values are used? Are there other considerations that should be assessed when evaluating whether to use forecasted values - and who provides those values? How will those costs be allocated or penalties for non-performance be assessed and how will those relate to forecasted values?

 Settlements, Measurements, and Validation

1.  Should DERAs be held to the same credit-worthiness tests and contracting requirements with MISO (or higher or lower) as other market products?  What types of risk are these new market participants bringing to the market, and is the penalty in relation to the risk? Inversely, are all benefits to the products being accounted for?
2. Would DERA be subject to the same non-performance requirements as all other resource types offering the same product?
3. How are non-performance penalties assessed for distribution company called reliability overrides? Who determines the validity of the override, and should the penalty change be based on valid or non-valid calls?
4. Is the created market participant type and tariff provisions reasonable and of practical use? Is it likely that the products are useable? (Evaluating whether a CAISO/CAPUC solution has been implemented, looks good on paper – but feasibly not useable/attractive to participants).  Do tariff provisions require technologies or capabilities that are too expensive for the market to bear, creating barriers to entry that make the order moot?
5. Is the final product as minimal as possible, as protective as necessary, involve and inform the right interested persons, and create a workable product without using unnecessary and/or onerous requirements?

Xcel Energy appreciates the opportunity to provide feedback on the Order 2222 Evaluation Questions.  Within the red-lined document we submitted, we have added questions we feel are critical to the evaluation of Order 2222 to the combined sets of questions .  Overall, we feel there needs to be a better understanding of the requirements and impacts from a Distribution Utility perspective.

MISO Order 2222 Evaluation Questions

Combined Initial Set and Additional Questions

Market Design

·         How should the range and variety of characteristics be represented in a resource type?

·         Should multi-node aggregations be accommodated?  What might be locational limitations?

·         Should market products be changed to accommodate DERs?

·         What are the appropriate DER aggregation and size limits?

·         How should distribution factors be considered for aggregated DERs? How does this impact congestion management?

·         How will pseudo tied assets be considered?

·         What are the implications to market mitigation?

·         How will costs be assigned to DER MPs?

·         Is there a reasonable multi-phase approach to implementation of market design?

·         What additional considerations are needed for a multi-resource DER aggregation to participate in the market? 

WEC Energy Group appreciates the work MISO has devoted to the list of evaluation questions associated with FERC Order 2222 and the wholesale market participation of DERs.  While MISO’s compliance filing obligations are fairly clear, we are concerned that individual state and RERRA distribution interconnection procedures may not contain language sufficient to ensure retail rate payers are not subsidizing DERs participating in the wholesale market.  A significant amount of coordination, accounting and data exchange is required between the DER, the distribution provider, the transmission owner, and MISO (as the transmission and energy market provider).  The coordination and data exchange will require the expenditure of both capital and O/M to maintain reliability and resiliency.  DERs participating in the wholesale market should bear these costs and take them into consideration when making a decision to participate in the wholesale market.  While LSEs and RERRAs are ultimately responsible to ensure retail rate payers are not subsidizing the participation of DERs in the wholesale market, MISO needs to provide a framework that allows identification and quantification of those incremental costs.

February 17, 2021

Midcontinent Independent System Operator, Inc.

720 City Center Drive

Carmel, IN   46032-3826

Re: Feedback on MISO Framework for Complying with Order 2222 

Dear MISO and Stakeholders:

Following the February 1st meeting of the Distributed Energy Resources Task Force (DERTF) for the Midcontinent Independent System Operator (MISO), MISO requested feedback on the draft framework that will support the “guiding principles” for stakeholders to evaluate mechanisms to with Order 2222, issued by the Federal Energy Regulatory Commission (FERC).  Voltus, Inc. (Voltus) provides the following feedback.

 To Voltus, the proposed framework is adequate to analyze proposals to comply with Order 2222.  Yet Voltus notes that it has been nearly five months since 2222 was first issued, and nearly four since notice was first published in the Federal Register.  The proposed framework could have been issued months ago.  Voltus requests that MISO move quickly to examine the substantive compliance issues, especially since MISO has already broadcast its intention to extend the deadline for its 2222 compliance filing.  

Regards,

/s/ Emily Orvis

_______________________

Emily Orvis

Senior Energy Markets Manager

Voltus, Inc.

(703) 785-8269 

emily@voltus.co