DERTF: Outage Coordination (IR070) (20211004)

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – OUTAGE 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 outage coordination. 

• Outage Coordination for a DER aggregation (DERa) 

• Currently, outage coordination of a DERa has no impact on Entergy Distribution Operations assuming that the DERa continues to operate within limits established in accordance with the Electric Distribution Company (EDC) Interconnection Agreement.  It is anticipated that this would hold true under the new construct.  However, with DERa participation in the MISO wholesale market under Order 2222, the EOC’s would agree that this has the potential to impact the MISO makets and that a framework for outage coordination needs to be developed.  When doing so, the EDC interconnection agreement should be taken into consideration.

The EOCs appreciate the opportunity to comment.

MISO proposes to manually study DERa (Distributed Energy Resource Aggregation) outages when the DERa is at least 10 MW [and auto-approve DERa outages when the DERa is less than 10 MW], which is consistent with MISO’s existing outage review process for generation facilities above 10 MW. However, MISO’s existing outage review process (per the Outage Operations Business Practices Manual, BPM-008-19) does not apply to Demand Response Resource - Type I or II. Why, then, is MISO proposing to apply the existing outage review process to DERas?

The OMS DER WG supports MISO’s early comments and indication that information on outages, and other DERa data, will need to be shared in some format with multiple entities. With both customer and grid data privacy and security needs in mind, the DER-owner, the DERA, the RERRA, the EDC, TOs, and MISO will need a coordinated effort to institute proper protections.. This should be an automated process, if possible.

The OMS DER WG discussed whether the 10MW threshold is too high for proper outage coordination impacts on the distribution system; while MISO is outlining what information needs to be coordinated with MISO, additional EDC coordination is likely needed depending on location and localized conditions and system design. There is likely not a set threshold at which outage coordination needs can be set at a MW-across the system.

For the Outage Coordination flow diagram, Xcel Energy recommends the following revision:

• In the EDC lane, "Communicate directly with DERA who will cancel or move DERa outage" should be changed to "Identify and communicate outages" and there should be an arrow to the DERA and an arrow to the DER (per EDC discretion, based on current conditions and future conditions).

To protect the Bulk Electric System, MISO should notify the Transmission Operator about all MISO-registered aggregations. Multiple aggregations feeding single nodes have the potential to create common mode impacts.

MISO should require outage submission by any DERas over 10 MW (because there is no size limit). If outages roll up to over 20 MW per node, MISO should notify the TO about the aggregate outage MW. These sizes may need to be adjusted depending on experience and location.

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