During the January 4, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the technical approach for Order 2222 compliance. MISO’s approach to Order 2222 will include a focus on an implementation to allow near-term DER integration with minimal system impacts. Stakeholder feedback is requested on the approach presented.
Please provide feedback by January 19.
During the January 4, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the technical approach for Order 2222 compliance. MISO’s approach to Order 2222 will include a focus on an implementation to allow near-term DER integration with minimal system impacts. Stakeholder feedback is requested on the approach presented. (Issue Tracking ID#: IR070)
Environmental Sector Response:
We appreciate MISO’s effort to provide stakeholders with a technical approach for Order 2222 compliance. In general, we support MISO’s product development process. However, we have questions and concerns about what the proposed technical approach might be missing and how it might lead to problems in the Order 2222 compliance process.
First, by limiting the “evaluation” phase to ways in which DERAs can be accommodated with existing participation models, the technical approach might fail to capture instances in which participation models need to be enhanced or expanded to get the most of DERAs. The approach ignores instances in which new bridges might need to be built between existing participation models. For example, DERAs that can serve as a dispatchable intermittent resource or a demand type resource depending on circumstances might require changes to existing participation models. While the existing participation models might be adequate to deal with such resources, it is important the MISO does not assume that the existing participation models will be static and siloed throughout this process.
Second, the technical approach does not reference MISO’s guiding principles for Order 2222 compliance. There may be times when solutions and/or opportunities come out of the technical approach that are in conflict or tension with other solutions and/or opportunities. It will be important to use the guiding principles to decide how to navigate those conflicts/tensions. MISO should include reference to the guiding principles as part of the technical approach.
Third, it is unclear how MISO will balance implementation plans with other initiatives. Does MISO have a priority stack for deciding which initiatives will take precedence in this balancing process? If so, what is that priority stack and how will MISO provide clarity on when it is used throughout the Order 2222 compliance process? If there is no priority stack, how will MISO resolve conflicts?
Sincerely,
The Environmental Sector
DTE is pleased to provide feedback to MISO on the DER guiding principles introduced during the 1/4 meeting of the DER Task Force.
With respect to its workplan, DTE has a few suggestions for how MISO can continue to push this project forward:
With respect to MISO’s discussion of potential participation pathways, DTE has some requests for clarification as well as some recommendations for how to structure the participation pathway evaluation:
MISO has also indicated that it may pursue an extension to the compliance timeline set out in the Order. If MISO were to pursue such an option, DTE would support MISO’s approach.
MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCES TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: EXPLORE STAGE APPROACH
DATE: JANUARY 19, 2021
At the January 4, 2020 meeting of the Distributed Energy Resource Task Force (DERTF), in discussing the potential pathways to DER Participation under Order 2222 using existing participation models, MISO appeared to favor DRR Type I as best-suited for DERs. If only one participation model could be selected at this time, Entergy would agree with MISO. However, since there are various resource types that could be potentially involved, a one size fits all approach would not be the preferred path forward.
The Entergy Operating Companies ("EOCs")[1]preferred approach would take into consideration potential differences in how resources are offered and how accreditation should be calculated. For example, would a generator and a solar facility that are on the distribution system be able to use the same offer construct, be held to the same performance standard, and receive appropriate capacity accreditation? In this vein, MISO should also consider how a resource’s pre-deployment output/consumption baselines should be calculated. Would it be more accurate to use measurements taken 2 hours prior to deployment vs using a “10 in 10” approach that the Demand Response Tool currently uses to determine a baseline? Also, should a DERA be required to register aggregations separately depending on the resource type (for example, an aggregation of smart thermostats)?
How these questions are addressed in MISO’s participation model will impact the details of implementation requirements, such as measurement and verification, and who is responsible for metering and telemetry. The Order[2] leaves these details to the discretion of the RTO/ISO, and how this data will be provided to and verified by MISO, needs to be discussed with MISO and MISO’s stakeholder.
Whether the capacity is offered through an ARC, a utility, or some other entity does make a difference, and the nature of the tariff and customer contract will impact the way the DERA operates in MISO. Entities offering the capacity should have some freedom to decide their best-fit market product. In addition, Energy Measurement and Verification capabilities change at different scales, as some things are more easily metered and telemetered than others, and this will impact settlement data and how it is submitted.
As MISO considers implementation issues, it is important to bear in mind that as participation increases, it will also become increasingly important that the DO has visibility into MISO’s dispatch, both for reliability and to ensure that wholesale payments are not double counting services provided to or by the DO.
Questions for consideration:
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
[2] See P 267, where FERC stated that: We decline the requests of some commenters to explicitly limit metering and/or telemetry requirements to the distributed energy resource aggregation level, or to require telemetry of individual distributed energy resources participating in an aggregation. Rather, consistent with the flexibility provided in Section IV.F, we will not require uniform metering requirements across all RTOs/ISOs, nor will we require each RTO/ISO to impose uniform metering requirements on individual distributed energy resources. Rather, we provide flexibility to RTOs/ISOs to propose specific metering requirements, including any that may apply to individual distributed energy resources that the RTO/ISO demonstrates are needed to obtain any required performance data for auditing purposes and to address double compensation concerns. Similarly, we provide flexibility to the RTO/ISO as to whether to propose specific telemetry requirements for individual distributed energy resources in an aggregation. The need for such requirements may depend, for example, on whether the RTO/ISO allows multi-node aggregations or how multi-node aggregations are implemented. By providing flexibility while also requiring that the RTO/ISO explain why any proposed metering and telemetry requirements are necessary, we allow the RTO/ISO to obtain the metering and telemetry information it needs without burdening the distributed energy resource aggregator to provide data that may not be necessary.
WPPI supports MISO’s proposed approach to its compliance with FERC’s Distributed Energy Resource Aggregation Order 2222 (20210104 DERTF Item 07 Stage Review). In particular, to comply with the order as quickly and efficiently as possible by leveraging existing participation models (e.g., Dispatchable Intermittent Resource, Demand Response Resource Types I and II, Storage Energy Resource Types I and II and the FERC approved Electric Storage Resource). After MISO has met the compliance requirements of Order 2222, MISO and stakeholders can consider and prioritize further enhancements to DER/A participation in MISO markets along with other potential market enhancements.
Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the technical approach for Order 2222 compliance that MISO presented at the January 4, 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 recognizes that MISO is in the “Explore” phase of the “Explore. Decide. Do.” process as outlined in the presentation at the January 4, meeting of the DERTF.[2] In that presentation MISO states that they have the goal of balancing the implementation of Order 2222 with other initiatives, which the AEMA can certainly appreciate. Preliminarily, MISO’s approach to evaluate existing market participation pathways to see how Distributed Energy Resource Aggregators (DERAs) might be accommodated to participate in the market through existing market models is a reasonable first step. There is no need to create new models if the existing models can adequately accommodate participation requirements. Utilization of existing models may allow quicker implementation of the requirements which would bring DERAs to the market sooner.
However, as MISO performs this evaluation, it is critical that MISO ensure that while fitting DERAs into existing models, that the models do not limit DERA participation in the markets or not take advantage of the full capabilities offered by DERAs. For example, MISO must be cautious to ensure that any “accommodation though existing participation models” will not create barriers to DERA participation in the form of unnecessary modeling conditions, metering requirements, and/or telemetry constraints.
FERC Order 2222 states the expectation that MISO will, “Allow DER Aggregators to register DER aggregations under one or more participation modes in the RTO/ISO tariff that accommodate the physical and operational characteristics of DER aggregation.” AEMA believes that DERs bring a broad range of operational benefits to the electrical grid and it is critical that MISO seeks to fold the uniqueness of those “physical and operational” characteristics into the model(s) of participation that are proposed. While the existing participation models is a reasonable first step in the evaluation of DERA modeling, it is important to understand that the current models will need modifications, some of which may be significant. Ultimately, it may be more efficient to simply develop a new model of participation.
The characteristics of a group of resources at a given site that includes, for example solar, battery storage and demand response whose operation is co-optimized and of aggregations of such heterogenous resources will, by definition, be substantially different than the characteristics of similar group of resources that must be operated in isolation based on market participation rules that assume homogeneity. AEMA believes that an Order 2222 compliance proposal that does not recognize this fact and provide for the aggregation of heterogenous resources must be found deficient.
As the premier industry association representing entities at the forefront of integrating and operating disparate types of distributed energy resources, AEMA is uniquely situated to support MISO and its other stakeholders on how (and, more importantly, how not) to structure a DER participation model that fosters the synergies that are possible and that will maximize the consumer and system benefits.
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
DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052
Consumers Energy appreciates the opportunity to provide feedback regarding MISO’s “Explore Stage” Approach to addressing the needs of the compliance filing requirement for FERC Order 2222.
MISO’s stated approach of accommodating Distributed Energy Resource Aggregators (DERAs) with existing participation models is practical and appropriate given the time constraints required for making their compliance filing. However, in an ideal scenario with more time available for development, designing and implementing new participation models would be a better approach.
There are too many variables which cannot be addressed under existing participation parameters for ideal DERA enablement. For example, a model DERA construct needs to include definitions and requirements around capacity. Aggregated assets could include many different types of resources, each with its own unique capacity characteristics such as how the capacity varies given the time of the year and what the actual capacity availability is compared to stated or “nameplate” availability. As a result, these aggregated assets should be subject to some level of performance testing so that their true impact on the system can be determined and both distribution and transmission operators can know what to expect when they are deployed. The current participation models do not contain such requirements.
Another variable that is extremely important to get right but which is unlikely to be optimally addressed under existing participation models concerns data. In order to enable DERA integration, data must be accurate, timely, secure and correctly specified. In other words, there needs to be data quality and the controls associated with it. Again, these necessities are unlikely to be properly captured using existing participation paradigms. In order to have accurate data, there needs to be a process by which the DERA, the utility, MISO and the Relevant Electric Retail Regulatory Authority (RERRA) can all agree on the quality of the data. To do that, the elements of data quality need to be defined and vetted. Once this step is complete, the data quality requirements need to be tested and then operationalized such that system safety and reliability is not only not compromised, but also improved. It would be difficult to achieve a data solution with ideal robustness using current participation models.
The above are but two examples of issues that likely cannot be addressed in an ideal manner using MISO’s proposed “Explore Stage” Approach. There are likely many others, including but not limited to customer rate impacts and affordability, change process for adding and subtracting customer enrollment and equipment improvements, definition of locational requirements, communication protocols, outage modeling and management, contractual agreements and other legal requirements and distribution override rights and responsibilities. In order to achieve an optimal end state a “Top-Down” methodology should be considered whereby MISO and the stakeholder community identify and define what effective participation models look like, without constraining themselves to the limitations of the existing Tariff. A top-down approach would begin with the identification of pertinent variables which need to be considered, many of which have been noted above. Once these are identified, they could then be defined. These first two steps provide a solid foundation from which the development of market constructs, testing criteria, operational conventions and, ultimately, implementation can be launched.
Thank you once again for allowing feedback on this important topic. Consumers Energy looks forward to continuing to work with MISO and the stakeholder community
MGE and MPPA generally support WPPI Energy's feedback.
Thanks,
David Sapper
dsapper@ces-ltd.com
The Michigan Public Service Commission (MPSC) Staff agrees with the comments filed by the OMS DERWG, particularly the feedback that MISO should immediately develop an issues list, work plan, and Gantt chart. The MPSC Staff would like to add the following to that line of thought.
Continued development of an issues tracking list and corresponding Gantt chart should be a high priority and could expand within the MISO’s Compliance Spreadsheet found here on the IR070 page. MISO should use this document to prioritize issues and list dates when topics would be raised at MISO meetings, allowing stakeholders time to assemble the appropriate subject matter experts (SMEs) for each particular meeting. This will be particularly important for stakeholders that do not regularly participate in MISO meetings, such as distribution operators. In addition, meeting agendas should be posted as soon as possible (even beyond the 5 days required by the Stakeholder Governance Guide) to ensure the appropriate SMEs are available.
MISO should make the Compliance Spreadsheet a live document, adding columns with additional information for each subject and meeting. These columns should include the date each topic will be raised at MISO meetings, the SMEs requested for that meeting (or detailed agenda), progress made thus far, links to relevant sections of the tariff, etc. Such an approach would give stakeholders a roadmap to follow as MISO develops its Order 2222 compliance under a tight deadline.
With regards to this tight deadline, the MPSC Staff would recommend to its Commissioners that the MPSC support any Request for Extension of Time that MISO files at FERC relating to Order 2222. The MPSC Staff is concerned at the pace of MISO’s Order 2222 compliance and believes more time will likely be needed to fully comply with FERC’s directives in a way that allows the issues to be fully vetted and explored.
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 evaluation of options. OMS DERWG acknowledges the short timeframe that exists for compliance and the work done by MISO to date. This feedback does not represent a position of the OMS Board of Directors.
The approach proposed by MISO and the Potential Participation Pathways outlined (DIR, DRR I and II, SER Type I and II, and ESR) appear potentially too limited to be a starting point for a gap analysis. The Potential Participation Pathways options do not include hybrid resources and may ultimately be insufficient and incapable of providing the foundation for the various resource offerings and market products that could be formed from a DERA. MISO should not limit itself to trying to fit DERA into existing resource offerings, rather, MISO should evaluate the most efficient participation model and develop tariff language accordingly. This may mean building a participation model from the ground up, within a new resource category, rather than relying on tweaks to existing tariff language. Regardless, due to timing, OMS DERWG believes the analysis should begin immediately on Order 2222 compliance, and the OMS DERWG acknowledges the balance MISO will need to strike between finding the perfect method to ‘start work’ – versus simply getting started. Due to the limitations of the proposed starting point, MISO should keep this in mind during the gap analysis, and contingency time may need to be allotted in the schedule to address and evaluate differences in resource type potential and attributes.
OMS DERWG is concerned about the (potentially delayed) timing and staging of the efforts in the DERTF, including the potential need for MISO to develop a new resource participation model type for Distributed Energy Resource Aggregations (DERA). Prioritization of compliance requirements will be key to deciding where time and effort should be spent. Additionally, providing sufficient advance notice to stakeholders of DERTF topics, dates, and questions to be answered or issues to be resolved at each meeting will be crucial.
The OMS DERWG suggests that a work plan and framework for evaluation should be outlined in conjunction with an issues list or matrix that outlines all the items that need to be tackled. The OMS DERWG finds the compliance matrix, and the overview provided at the January DERTF to be a good starting point. However, a straw work plan, issues list, and issue prioritization need to be outlined for input as soon as possible. These items would also assist with DERTF meeting planning, which will be particularly important considering the need to coordinate with atypical MISO stakeholders, such as distribution system operators and DER Aggregators. Developing a work plan and posting meeting agendas as soon as possible (even beyond the 5 days required by the Stakeholder Governance Guide), would give stakeholders more time to ensure the appropriate subject matter experts are made available for each call.
OMS DERWG recommends MISO use Gantt charts (as soon as possible) to help plan when key decisions need to be made by stakeholders and MISO. This chart could list when each specific Order 2222 requirement would be tackled at specific DERTF meetings, which would help ensure that the appropriate subject matter experts, particularly at the distribution level, are able to be in attendance (or could plan now to attend multiple DERTF or Distribution Coordination meetings). MISO should include and articulate when and what decisions it would need to make itself through this process. This chart would be used by stakeholders to ensure that all issues are addressed and included.
Xcel Energy appreciates the opportunity to provide feedback on the technical approach for compliance with Order 2222. In general, we are supportive of MISO's plan to use the existing market participation models as a starting point for evaluation. We would also recommend that MISO leverage Attachment HHH which was developed for ESRs located at the distribution level.
WVPA is fine with the approach as stated. There will need to be extensive work done to ensure existing DERs can comply with new requirements. Work to ensure distribution companies can comply with new requirements will be very important; not all utilities in the MISO are vertically integrated. Maintaining our relationship with our customers is of the utmost importance to us and care should be taken to preserve that relationship.