Xcel Energy appreciates the opportunity to provide feedback on the Order 222 Guiding Principles.  We are supportive of the guiding principles as presented, but recommend that the word "safe" be added to the first principle and use this principle to account for wholesale and distribution operations.  With this revision, the first principle would read:   "Identify DER-related issues with existing markets, tools and processes to ensure continued safe, reliable and efficient wholesale market operations and distribution operations."

During the January 4, 2021, Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the FERC Order 2222 guiding principles.  These guiding principles will be used to evaluate potential solutions for compliance.  Stakeholder feedback is requested on the guiding principles that were presented. (Issue Tracking ID#: IR070)

Environmental Sector Response:

We appreciate MISO’s effort to provide stakeholders with these guiding principles for Order 2222 implementation. While we are generally in favor of the draft principles presented, we have questions about the principles, edits of an existing principle, and recommendations for additional principles we think it is important for MISO to adopt. Our goal in presenting these principles is to ensure that the principles provide guidance on how to select solutions to all the Order 2222 compliance requirements. Overall, we are concerned that the guiding principles are focused on mitigating “DER-related issues” to the exclusion of identifying and eliminating DER barriers.

Questions:

• Are the guiding principles ordered in any kind of priority?
• If the guiding principles are not ordered in priority, how will MISO resolve instances where principles come into conflict on any given compliance decision, due to technical, legal, timing, or other reasons?

Changes to MISO’s proposed principles (additions underlined):

3. Address any DER-related issues impacting such resources' participation in MISO's wholesale markets with reasonable solutions that enhance or support reliability and market efficiency without imposing unnecessary burdens/costs and commensurate with the particular DER type/grid service, while complying with applicable orders, regulations and jurisdictional requirements. 

Additional guiding principles:

• Develop clear, transparent, and flexible parameters to eliminate identified barriers to DERs in the existing markets, tools, and processes while allowing for broad participation.
• Identify and eliminate barriers to DERs in the existing transmission planning protocols, tools, and processes.
• Allow DERs to participate in both wholesale markets and retail programs while preventing double-counting of service. Enable dual participation through clear and flexible bidding parameters, wholesale market financial incentives and penalties, and operational coordination among the RTO, distribution utility, and DER provider.
• Information and metering related requirements must be tailored to meet specific needs for different DER types and grid services; ensure clarity, transparency, and flexibility towards meeting these requirements; and be focused on the aggregate level.
• Model and analyze transmission system upgrades/solutions, including multi-party solutions, that optimize DER benefits and lower costs for new DER capacity/entry.

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.  

MISO's guiding principles as currently worded do not clearly articulate the criteria against which potential solutions should be evaluated.  Here are some wording edits that might make these principles a bit more direct:

• DER solutions should support or enhance the reliability and efficiency of MISO's operations
• DER solutions should support the safety and reliability of MISO's connected distribution utilities
• DER solutions should support communication and coordination among stakeholders, and stakeholders' respective roles and responsibilities should be clearly defined and in alignment with other industry functional models to the extent practical
• DER solutions should be compliant with applicable orders, regulations, and jurisdictional requirements
• DER solutions should align with current and future resource and transmission planning initiatives, including those being developed in response to MISO's Reliability Imperative

Consumers Energy appreciates the opportunity to provide feedback on MISO’s “Guiding Principles” that will be used to evaluate potential Distributed Energy Resource (“DER”) solutions.  Generally, the proposed principles would benefit from additional specificity and clarity.  As drafted, any solution could easily meet all four guiding principles, making it difficult to preference or compare potential approaches.   

Specifically, the first principle should affirm that a proposal enhances grid flexibility and provides transparency to support reliable distribution and transmission system operations.   

The second principle should confirm that a solution is the product of distribution utility and state regulator discussions and provides clearly defined roles and responsibilities for the transmission system operator, distribution operator, and aggregator.   

Regarding the third principle, MISO does not (and rightfully so) determine whether resource participation complies with state or federal orders, regulations, and jurisdictional requirements.  Those determinations are made by Relevant Electric Retail Regulatory Authorities and the Federal Energy Regulatory Commission.  Accordingly, this principle should be modified to confirm that a proposal “removes wholesale market barriers for DERs and respects state rights to enact clean energy policies and retail customer programs”.    

Further, the last principle should be clarified to affirm that a solution can be integrated in, and accounted for, in MISO’s resource and transmission planning processes.    

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the Order 2222 Guiding Principles 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.

At the January 4 meeting of the DERTF, MISO staff presented a set of guiding principles that will be used to evaluate potential solutions. While the initial guiding principles appear to represent a reasonable start, AEMA would suggest that the proposed criteria are focused on integrating into “existing” markets; creating “frameworks to ensure awareness of opportunities and challenges;” and “complying with applicable orders, regulations, and jurisdictional requirements.” These criteria are focused on the perspectives of utilities, MISO system operators, and compliance with some, but not all of the regulatory requirements including Order 2222. 

Simply put, the initial principles focus overmuch on what has been done and not what can be done. MISO will not reach the dynamic world envisioned by FERC in Order 2222, where customer flexibility is fully animated by focusing its attention on the rearview mirror. New perspectives are going to be required.

One such critical perspective that is currently missing is that of the DERA. Concerns about capturing the viewpoints of providers who have not historically participated in the MISO stakeholder process were expressed by multiple individuals at the December 2020 Advisory Committee Hot Topic discussion. MISO should enhance these guiding principles to include criteria on whether a proposed solution captures the full value of a DER and whether it accommodates the broad spectrum of DERs that might be represented by DERAs. 

Given the significant investment of resources that is now focused on the implementation of Order 2222, this is the unique opportunity to create a process that captures the full value of DER into the future and prevents the need for a deep dive into this issue again in the future. In considering any potential solution, MISO should add a fifth criteria. 

“Ensure DER providers are able to utilize appropriate strategies to manage their energy costs while also integrating into all capacity, energy (including Real Time) and ancillary services markets without unnecessary administrative barriers.”

AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 Guiding Principles 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

MGE and MPPA generally support WPPI Energy's feedback.

Thanks,

David Sapper

dsapper@ces-ltd.com

The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback in regards to MISO’s effort to frame the guiding principles that will be used in evaluating the potential solutions to comply with FERC Order 2222.  In response to this feedback request, the EOCs offer the following comments.    

MISO’s Guiding Principles should begin by reflecting a clear picture of existing roles and responsibilities and discussion on what will change with the implementation of Order 2222.  Using this as a starting point will create a framework for discussion regarding the implementation that will not be the subject of further debate regarding details such as:

• Measurement and verification of services provided
• MISO communication with Distribution Operators (DO) and DO visibility into MISO’s dispatch instructions
• Retail regulatory tariffs, orders, requirements, restrictions
• Clear expectations of roles and responsibilities of parties involved during MISO registration, operating events and the MISO settlements process.

Regarding MISO’s proposed Principle #1, MISO has gathered a good deal of input from stakeholders relating to issues with the current market products available for DERs, and this input should be leveraged in the discussions regarding DER-related issues and in evaluating how DERAs can be accommodated within existing participation.

Finally, strong consideration should be given to the level of oversight that will be expected from MISO and the IMM regarding participation of DERs and more generally demand response in the MISO market.  While many individual DER registrations may be small in size, demand response collectively in MISO could be sizeable and should command appropriate oversight to prevent market manipulation.

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 guiding principles (GP).  This feedback does not represent the position of the OMS Board of Directors.

OMS DERWG is seeking to ensure stakeholders find value in developing principles. The OMS DERWG recommends that limited time be dedicated to the guiding principles during the next DERTF meeting.

If pursued, the GPs should help facilitate discussions in the DERTF and direct MISO’s decisions on complying with Order 2222. Additional context on the purpose and use of the principles would be useful (as well as their applicability to DER issues outside of Order 2222), how they would be applied, and for what purpose. Several members were concerned that the guiding principles, as is, went beyond the scope of Order 2222 (specifically, GP 4).

There was consensus from our workgroup that GPs should provide a framework for decisions (versus being action or goal focused) and should not duplicate the DER TF mission and charter. Again, if pursued, the OMS DERWG suggests that the GPs be used to create a framework for decision-making and outline factors to evaluate potential solutions. In evaluating and determining appropriate proposals, MISO's proposed solutions should be:

1. Simple, low cost, and technically feasible;
2. Supportive of reliable and efficient electrical system operations, including necessary coordination with the appropriate entity (GP2 and 3);
3. Clear from a jurisdictional perspective, i.e. properly delineated to not impede or limit decisions by the states and not acting as a barrier to the states’ role in assuring retail ratepayer protections;
4. Transparent in assumptions and responsive and reflective of stakeholder feedback;
5. Discrete and sufficiently defined;
6. Free from unintended market, planning, or operational effects;
7. Supportive of and aligned with larger MISO initiatives;
8. able to address DER-specific issues relating to market participation (GP3);
9. Aligned with, enhance, and support reliability and market efficiency (GP3); and
10. Compliant with applicable orders (with clear connections to compliance with Order 2222), regulations, and jurisdictional requirements (end of GP4).

The proposed guiding principles to inform MISO’s compliance with FERC Order 2222 appear reasonable to WPPI (20210104 DERTF Item 04b Guiding Principles Work Plan). In brief, the principles are: (1), (3) accommodate Distributed Energy Resources while maintaining reliable and efficient operations and complying with all requirements (applicable orders, regulation, jurisdictional); (2) collaborate/coordinate with stakeholders, including distribution utilities; (4) support current and future resource, transmission planning, etc. initiatives. The one suggestion we have is in guideline (4) to replace “Reliability Imperative” with more readily accessible terminology.

MISO’s guiding principles must contain not only collaboration and coordination with distribution entities, but elements to ensure distribution entities are able to maintain reliability, compliance with RERRA requirements, and recover applicable costs from aggregators of DER. MISO’s compliance with Order 2222 will require unprecedented partnership with distribution entities and their Relevant Electric Retail Regulatory Authorities (RERRAs). WEC Energy Group suggests the following addition to MISO’s guiding principle #2:

Establish and support collaboration and coordination frameworks with stakeholders, including distribution utilities, to ensure awareness of opportunities and challenges, to ensure distribution entities are able to maintain reliability, maintain compliance with RERRA requirements, and recover applicable costs from aggregators of DER, and to facilitate technical coordination, policy conversation and education.

WVPA feels the guiding principles are fine as stated.