DERTF: Measurement and Verification (IR070) (20211101)

During the November 1, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO recommended using existing measurement and verifications (M&V) protocols as described in Attachment TT for demand response in a DERa.

ITC Response:

Anticipated increases in Demand Response Resources and Distributed Energy Resources (including aggregations) as well as LMRs and EDRs in the footprint should encourage MISO to consider more stringent measurement and verification protocols to document performance. Specifically, response should be measurable, measured, and verified as are the responses of other Resources with which the Distributed Energy Resource aggregations (DERas) will be competing at the time of their deployment. This requires measurement before, during and after the deployment.  Situational awareness and system security would be enhanced by a more complete understanding of the actual performance of DERas. Attachment TT as it stands appears inadequate to support operator situational awareness and accurate settlement for services.

Details:

The response of Resources defined in MISO Tariff Module 1 is straightforward and the epitome of measurement and verification: 

"Actual Resource Response: The actual movement, in MWs, relative to Setpoint Instructions for a Resource within a Dispatch Interval."

Note how this definition requires measurement “the actual movement, in MW” and performance--the movement that is measured “relative to Setpoint Instructions” by Dispatch Interval. 

Contrast this with the entire Attachment TT that is a torturous description of various statistical analyses based on historical performance that presume to represent real-time performance of DERa components.

From Attachment TT

“Because it is impossible to directly measure the energy that a non-BTMG DRR, LMR, or EDR would have consumed in the absence of the Setpoint Instruction, Scheduling Instruction, or EDR Dispatch Instruction to reduce load, Measurement and Verification criteria are used to determine the performance of DRRs LMRs, or EDRs. Performance will be imputed through comparisons between the DRR’s, LMR’s, or EDR’s consumption baseline (as described below) and the DRR’s, LMR’s, or EDR’s actual hourly Metered energy.” [Attachment TT at 2, Performance Assessment]

From this it appears that MISO is proposing to use “actual hourly Metered energy” rather than a Dispatch Interval-based measurement.

Question: Does MISO intend to modify Attachment TT to recognize 5-minute dispatch instructions and the corresponding 5-minute response verification?

If MISO does not envision changes to TT for DERa to make the measurement and verification more granular, and in real-time, it seems like the Bulk Electric System is being increasingly positioned up imprecise operation which could potentially impact, but may not be limited to, such things as frequency management, Area Control Error, and system Regulation needs and deployment.

The current Attachment TT defines different types of Consumption Baselines against which imputed response is compared to evaluate performance. The Metered Generation Baseline definition appears to allow technologies such as aggregations of rooftop solar, or vehicle chargers to be calculated against a baseline instead of metered.  Note that Attachment TT requires that “all behind the meter generation must use this measurement and verification methodology.”  This statement precludes entities that may want to employ more granular measurement from using same. If MISO intends to rely on Attachment TT, perhaps this should be a minimum standard rather than precluding more granular and potentially better, measurement.  

Attachment TT

3. (i) Consumption Baselines for Energy and Calculated Output

(a) Metered Generation Baseline

This type of consumption baseline only applies to behind-the-meter-generation. All behind-the-meter-generation must use this measurement and verification methodology. For a DRR, LMR, or EDR that combines behind-the-meter-generation and non-behind-the-meter-generation, this consumption baseline applies only to the BTMG components. [Attachment TT, emphasis added]

With increases of technologies such as rooftop solar, and electric vehicle chargers that could be aggregated to form resources that inject to the system, it seems like requiring such resources to use calculated baselines rather than measuring actual performance is missing an opportunity to increase the precision and understanding of system operations.  We encourage MISO to explore and require more granular measurement of such resources.

Attachment TT

3. (i) Consumption Baselines for Energy and Calculated Output

(b) Calculated Baseline

For a DRR, LMR, or EDR not supported by behind-the-meter-generation, the consumption baseline is a profile of hourly demand based on an averaged sample of historical data, which may be adjusted for factors that reflect specific, on-the-day-dispatched conditions, such as weather. Unless the Market Participant registering the resource submits an alternative consumption baseline for the Transmission Provider’s approval, the Calculated Baseline will be determined as follows:

• Separate hourly demand profiles will be determined for (1) non-holiday weekdays and (2) for weekends/holidays.
• The weekday hourly profile will be based on the average of the ten (10), but not less than five (5), most recent weekdays that are not holidays or other non-standard “event” days. The weekend/holiday hourly profile will be based on the average of the four (4), but not less than two (2), most recent weekend days or holidays that are not “event” days.
• An “event” day is one during which there was, for the Resource in question, a real-time energy or ancillary services dispatch, an emergency deployment, or a reported Outage.

 .....

This requirement appears problematic in several respects. First, it appears to require MISO to be able to adjust multiple parameters for performance of multiple DERas and multiple components of DERas ---potentially on a daily basis--as presumably such resources would be offering daily and thus 'event days' could be every day. Has MISO considered the staffing demand that this definition might impose?  Second, as noted above, with increasing volumes of entities aggregating and providing response using sophisticated controls, it seems that a standard of actual measurement could be imposed. As Order 2222 contemplates DERas of a size of 0.1MW, how does MISO propose to ensure that the actual resource response is measurable and measured for settlement?  Third, the definition above appears to envision that such resources will only be dispatch infrequently, on so called “event” days. Is this plausible?

For the above reasons, we have concerns about the use of Attachment TT as it currently stands for the measurement and verification of DERa performance.  

Consumers Energy appreciates the opportunity to provide feedback regarding MISO's recommendation to use existing M&V protocols as described in Attachment TT for Demand Response in a DERa.

CE generally supports WPPI's feedback.

Attachment TT enhancements will likely be necessary to address possible dual participation opportunities and challenges related to measurement and verification not currently prescribed.

Xcel Energy supports MISO's proposal to utilize existing M&V protocols as described in Attachment TT for demand response in a DERa.   In addition, any revisions made to this Attachment in the future should continue to apply to all demand response.

Please see email attachment for full feedback.

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – MEASUEMENT & VERIFICATION
DATE: NOVEMBER 15, 2021

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the November 1, 2021 Distributed Energy Resource Task Force (DERTF) meeting concerning FERC Order 2222 filing framework and the related topic of measurement and verification (M&V).

Measurement & Verification (M&V)

• In response to MISO’s proposed use of existing M&V protocols to measure demand response included in a Distributed Energy Resource aggregation (DERa), the EOCs think that MISO should further explore and ultimately adopt the use of before and after metering for all resource types instead of relying on baselines.  Customer baselines allow for the possibility of payment for performance that did not take place, e.g., the “meter before” measurement being different from the customer baseline, and this risk can be eliminated through the use of actual meter data comparison.    

The EOCs appreciate the opportunity to comment.

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the feedback request made by MISO at the November 01, 2021, meeting of the DERTF.[2] 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.

At the November 1 meeting of the DERTF, MISO presented their recommendation for using the existing Measurement and Verification (M&V) protocols as described in Attachment TT of the MISO Tariff for Distributed Energy Resource (DER) aggregations. Attachment TT identifies multiple consumption baselines that include direct meter, meter before/meter after, firm service level, 10 in 10 (with adjustment options), direct load control, and custom approaches.

AEMA supports this recommendation by MISO as fair and reasonable. AEMA would like to request MISO address the following clarifying questions on the M&V approach. 

• At what interval will a DERA be able to shift baseline methodologies after initial registration? Will changes to the consumption baseline require a DER review by DU (like initial registration)?
• Is 5-minute settlement meter data required for DER Aggregations providing only Capacity and/or Energy response (with no Ancillary Services)? Are there options for hourly settlement meter data when only offering Capacity and/or Energy?

AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed at 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 discuss 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

Voltus Comments to MISO November 01, 2021 DERTF Feedback Request

MISO defines DERA as Aggregator of DER. And DER with a small a "DERa" as DER aggregation.

MISO requested stakeholder feedback on the following:

1. Measurement & verification - Utilizing existing M&V protocols as described in Attachment TT for demand response in a DERa.

Voltus supports utilizing existing M&V protocols as described in Attachment TT for demand response in a DERa. Voltus takes this opportunity to emphasize that baselines and performance M&V should be applied to individual DERs or DER groups and then aggregated across a DERa. This proposed order of operations will improve the accuracy of M&V for resources on baselines with adjustment factors (symmetric multiplicative or weather adjustments). Adjustment factors can be different, in both degree and direction, for different resources within one aggregation.  

In addition to using the M&V protocols in Attachment TT for the demand response contribution of DERas, MISO should use the same methods to measure net injection to the grid for heterogenous DERs that both curtail and inject. As slide 11 of our straw proposal presentation to the DER task force in May showed, existing DR M&V methods can capture injection as well if net load measurements can be reflected as negative values when a DER is injecting to the grid. DER aggregators, MISO, and all stakeholders would benefit from the simplicity of having a single M&V protocol for the full contribution of an aggregation. (Voltus’s May presentation is available here: https://cdn.misoenergy.org/20210510%20DERTF%20Item%2004%20MISO%20Straw%20Participation%20Model_Voltus548198.pdf ).

2. Registration coordination framework.

No comment.

3. Operations & outage coordination framework.

No comment.

4. Dispute resolution.

No comment.

5. MISO is also requesting feedback on “use cases” presented, including the solicitation of additional use cases for review and the application of existing use cases to anticipated DERas.

Voltus shared 3 use cases in response to the August 2 DERTF stakeholder feedback request (available at:  https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/dertf-filing-framework-document--iteration-2-ir070-20210802/ ). The 3 use cases demonstrate:

1.      It is feasible to use existing baselines established for demand response programs for all DERs.

2.      Established DR M&V can be used for a single DER with multiple underlying technologies & one point of metering.

3.      Established DR M&V can be used for an aggregation of many DERs with varying underlying technologies.

WPPI supports using the existing measurement and verification protocols as described in Attachment TT for demand response in an aggregation of distributed energy resources (DERa). To the extent enhancements are made to Attachment TT, they should apply to all demand response regardless of the vehicle used to participate in MISO.