DERTF: Normal Operations (IR070) (20211004)

On the RT Operational Coordination flow diagram, Xcel Energy would recommend the following revisions:

1. In the EDC lane "Perform RT distribution system reliability analysis", add "based on EDC’s specific capabilities/procedures" to the end
2. In the EDC lane "Identify and communicate DER limitations to DER aggregator" should be revised to "Identify and communicate DER limitations" and there should be an arrow to the DERA and an arrow to the DER  (based on current conditions and future conditions).
3. For DA and RT limitations: Is there a threshold for the EDC to report limitations to the DER or DERa?  Some limitations may be insignificant and unnecessary to report. 

Additional coordination and discussion is required to determine required timelines, communication pathways and involved parties for DERA Normal Operations. This may also depend on size and location of the DERA and may be defined through interconnection agreements and/or RERRA requirements. 

Generally speaking, WPPI finds MISO’s proposed day-ahead and real-time operational coordination of DER(s) (individual Distributed Energy Resource(s) in a DERa), DERa (DER aggregation), DERA (DER Aggregator), EDC (Electric Distribution Co), TOP/LBA (Transmission Operator/Local Balancing Authority), and MISO reasonable. That said, WPPI offers a couple of comments:

(1.)  Both the proposed day-ahead and real-time coordination appear to have the TOP/LBA and MISO communicating with EDC. However, in the case of some EDCs, an entity other than the EDC is responsible for the EDC’s participation in MISO and the EDC does not directly communicate with MISO.

(2.)  Our current expectation is that our members (or WPPI) would communicate with any DERAs with DERas on their distribution system vs. individual DERs. (WPPI is wholesale supplier to municipal utilities and one cooperative in WI, Upper Peninsula of MI, and IA.)

Slide 94: One area the OMS DER WG keyed in on was that the one-hour ‘after DA before rebid closes’ timeframe for EDC review may be too short. States in OMS that have operational experience with this type of distribution/wholesale coordination, both on the electric and gas sides, have noted that there are often issues with obtaining accurate information from a third party in that short of a time frame. The additional entities that are needed for coordination either need automated systems, or additional time for issues to be resolved.

The OMS DER WG also discussed existing systems for data sharing, like Green Button Connect, are useful starting points, but additional vetting of those programs, and whether they are comprehensive enough to share all the pieces of data that might be needed to be shared with multiple entities will be needed.

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – NORMAL OPERATIONS COORDINATION
DATE: OCTOBER 18, 2021

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the October 4, 2021 Distributed Energy Resource Task Force (DERTF) meeting concerning FERC Order 2222 filing framework and the related topic of normal operations coordination. 

• Normal Operations - Day-Ahead and Real-Time Operational Coordination 

• Coordination activities and any changes needed to the Electric Distribution Company (EDC) systems and processes as a result of compliance with Order 2222 should be driven by the Relevant Electric Retail Regulatory Authority (RERRA), as well as the individual EDC and its interconnection agreement with the Distributed Energy Resource aggregation (DERa)/Distributed Energy Resource Aggregator (DERA).  The EOC’s EDCs have and will continue to provide a range of operation for Distributed Energy Resources (DERs)/Distributed Energy Resource aggregations (DERas) under the interconnection process.  Therefore, it is anticipated the EOCs EDCs will not need to be involved with day-to-day coordination activities under normal operating conditions.      
• Currently, and as we move forward under Order 2222, the individual EOCs EDCs reserve the right to disconnect any interconnected DER/DERa at their discretion to preserve the reliability of the Distribution Network.  

The EOCs appreciate the opportunity to comment.