DERTF: Modification of Resources in an Aggregation (IR070) (20210830)

MISO’s recommendation to use a 4x/year cadence in allowing DERAs to modify the DERs in which make up a DERa may need additional to support on why it cannot be more frequent at this time. If there are reasons for the infrequent cadence, beyond what was provided in the slide presentation, explanation to the DER TF would be useful. Regardless, a clear plan and dates for allowing more frequent updates once the Model Manager is up and running (post 2022) should be documented in the filing to FERC. This feedback does not constitute a position of the OMS Board of directors.

OMS assumes that limiting updates to only 4 times a year is likely driven by the level and specificity of data MISO will require from DERAs on the individual DERs within each aggregation. It is likely that DERs, and DERAs, will be seeking maximum flexibility in their participation. The more flexibility MISO can provide, the higher chance this product will be used. Potential modifications to a DERA’s aggregation may be minimal and creative approaches that maximize flexibility while ensuring reliability is key and should be encouraged.

The OMS DER WG appreciates the benefits of allowing a modification to an existing DERA registration in lieu of DERA re-registration. However, the OMS DER WG understands the 4x/year update frequency to DERs in a DERA, may not be sufficient for DERAs and a more frequent update cadence may be necessary to truly enable a useable DER product.  A less frequent update (4x/year) may be useful at the onset to allow streamlining of the coordination aspects, but it must be followed with an intentional and planned timeframe for improvements to the updated cadence. The OMS DERWG appreciates MISO’s goal to eventually allow updates 8x a year or monthly (Slide 84) and encourages MISO to include these milestones and timeline in its compliance filing.

DTE is pleased to provide the following feedback on various aspects of MISO’s latest filing framework for compliance with Order 2222.  Our full response will be provided via attachment.

Alliant Energy is comfortable with MISO's proposal regarding aligning DER aggregation changes to topology model updates (proposed to be quarterly).  In the future, MISO can consider with stakeholders the need and ability to increase this frequency.

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 August 30, 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.

In the August 30 meeting of the DERTF, MISO stated that it intends to only allow aggregators of DERs to change the makeup of their aggregation, e.g., adding or removing individual distributed energy resources when topology model updates are made (four times per year). AEMA does not support MISOs plan for limiting the opportunities for DERAs to make modifications to the resources in their aggregation and would request MISO to consider the following.

• There is no reason to wait for topology model updates because MISO is not modeling the individual DERs associated with at DER Aggregation (DERa). Once the DERA establishes a DERa participation model, the addition (or subtraction) of resource will only change the response capability of the asset. Adding or subtracting resources will expand or contract the participation in much the same way that a generator might change the generator capabilities. 
• Limiting updates to only four per year creates a barrier to DERA participation because the delay in getting new resources into the market is significant. For example, adding a new DER to a DERa would take many months before the resource could be utilized in the market when measured from the time of registration through model updates. This extended time frame diminishes the customer incentives to enter the market quickly and for MISO customers to take advantage of the benefits.  
• A DERA may have hundreds of individual DERs participating in a single DERa and these individual DERs may shift in and out of participation based upon consumer preferences. Creating a long delay in modeling of the resources will create inaccurate participation models for MISO. Shorter intervals for updating the model will make the participation model more reflective of the available resources. 
• Increasing the frequency of model updates will improve reliability and reduce barriers to participation of DERAs. MISO should revise its proposal to allow updates at a minimum of eight times per year and potentially monthly. With more frequent model updates, the participation model will be more accurate and will improve operational reliability.

In addition to the stated feedback, AEMA would like to request that MISO clarify whether the MISOs proposed “Groups/Sub-Groups” of DERs that comprise a DERa would be added/subtracted using this same modification procedure. For example, would a DERA with an existing DERa that wanted to add a resource type/group that is not currently part of the DERa use this same process to add the new DER(s) and DER Sub-Group? 

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 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

WPPI supports MISO’s proposal to align changes in a DER aggregation with topology model updates, which is currently four times per year. It seems logical to group changes in a DER aggregation with topology model updates, it avoids introducing another set of due dates, and it provides for updates on a relatively frequent basis.

TO: MISO DER TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: MODIFICATION TO LIST OF RESOURCES IN AGGREGATION
DATE: SEPTEMBER 15, 2021

In response to MISO’s questions concerning modification to list of DERs in an aggregation under FERC Order 2222 as presented in the August 30, 2021 DERFT meeting, The Entergy Operating Companies ("EOCs")[1] offer the following comments.

How often can aggregators change the makeup of their aggregation; e.g., adding or removing individual distributed energy resources?  1. Aligned with topology model updates (4x/year); 2. Aligned with topology and non-topology updates (8x/year); 3. Monthly (12x/year); 4. Annually (1x/year)?

The EOC’s agree with MISO’s proposal, that given the choices above, that an aggregator should be able to update the list of individual Distributed Energy Resources (DERs) in their aggregation on a quarterly basis in conjunction with topology model updates.  This quarterly timing strikes an appropriate balance for all involved.  This approach would also benefit from aligning with other MISO processes, models, and expectations of other resources. 

The EOCs appreciate the opportunity to provide input.