DERTF Resource Accreditation (IR070) (20211004)

The Michigan Public Service Commission Staff (MI PSC Staff) thanks MISO for allowing us to submit comments on the October 4^th DERFT Feedback Requests from the October 4 Order 2222 RA Review Presentation, accessed October 11, 2021. We are in agreement on the revisions to include the “Sum of the parts:  Underlying DER will receive credit according to resource type.  Aggregation will be accredited based on the summation of the underlying DER accreditation values.” However, we understand that this accreditation process is still in works at the  Resource Adequacy Subcommittee and thus do not know currently what the sum of all of the parts will be, which could be an issue for some stakeholders.

Advanced Energy Management Alliance

MISO Distributed Energy Resource Task Force (DERTF)

“FERC Order 2222 – MISO Resource Accreditation Proposal (20211004)”

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 October 04, 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 October 4 meeting of the DERTF, MISO presented their proposal for Distributed Energy Resource Aggregators (DERAs) to participate in MISO’s capacity market in conjunction with compliance with FERC Order 2222. In that presentation, MISO recommended allowing “DER to aggregate up to a minimum of 0.1 MW as a capacity resource (non-LMR). Aggregation would be up to EPNode and mapped to CPNode, consistent with the commercial model.” AEMA recognizes that MISO is broadly proposing to limit DER aggregations to the EPNode level. AEMA believes that this limitation represents a significant barrier to DERA participation in the MISO Energy and Ancillary Services Market and now MISO is proposing to add this to the Capacity Market. While this Resource Accreditation proposal may be consistent with MISO’s ASM limitations, there is not a technical reason for this limitation to exist in the Capacity Market and MISO should allow for DER Aggregations to aggregate to the Resource Adequacy Zonal level. 

MISO has also recommended that heterogenous aggregations be accredited for capacity using a “sum of parts” methodology, where “underlying DER will receive credit according to resource type. Aggregation will be accredited based on the summation of the underlying DER accreditation values.” AEMA supports this methodology as suggested by MISO as fair and reasonable.

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

The Organization of MISO States Distributed Energy Resources Workgroup (OMS DER WG or DER WG) appreciates this opportunity to provide feedback. These comments do not represent the position of the OMS Board of Directors.

The OMS DER WG agrees with other commenters at the October DER Task Force meeting that requested matrixes or charts outlining the differences between accreditation types between, at a minimum, the new DERa (DER Aggregation) resource type, co-located resources, and hybrid resource accreditation methodologies. Additionally, while this information is helpful for resource accreditation, other comparative charts for the new DERa resource type attributes (beyond simply resource accreditation) in comparison to other MISO market products would be a helpful resource for all stakeholders both now, as we evaluate DERa-attributes, and for future purposes including RERRA evaluation of utility investments (both grid infrastructure and individual DER-requests) and for utility and DERA’s long-term market participation decisions.

WPPI finds MISO’s proposed approach (“sum of the parts methodology”) to capacity accreditation for a DERa (Distributed Energy Resource aggregation) reasonable. (Sum of the parts: summing the unforced capacity values for each of the resource types included in the DER aggregation.) This approach would accommodate changes in the share various resource types make up of a given DERa over time.

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK - RESOURCE ADEQUACY
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 resource adequacy. 

• Resource Adequacy – MISO’s proposed use of a sum of the parts methodology for accrediting a Distributed Energy Resource aggregation (DERa) in the capacity market 

• The EOCs would agree with the points raised in the latest DERTF meeting, that the makeup of the resources in a heterogenous Distributed Energy Resource aggregation have the potential to change from one resource auction to the next making it difficult to measure aggregated performance from planning year to planning year.  As such, the EOCs agree with MISO’s “sum of the parts” recommendation using the underlying Distributed Energy Resource accreditation values.  However, the unique nature of DERas and their related measurement and verification methods might require additional considerations.  This would include the use of Electric Distribution Company (EDC) metering in any related testing and verification done as a part of the accreditation process.

 The EOCs appreciate the opportunity to comment.

Xcel Energy is supportive of allowing DER to aggregate as a capacity resources at the EP node level. 

MISO has also proposed that the capacity accreditation for DERa would always be based on the sum of the Planning Resource types within the DERa.  Planning Resource types include:  Capacity Resources, LMRs and Energy Efficiency Resources, so this would assume that the  existing requirements for capacity accreditation  for each of these types would be applied to the DERa capacity accreditation.  Is this correct?

Consumers Energy supports a sum of parts methodology for accrediting DERA in the capacity market.

DTE is pleased to provide the following feedback on various aspects of MISO’s latest filing framework for compliance with Order 2222.  The responses below address various questions and feedback requests raised by MISO.  MISO’s questions and proposals for feedback are captured in blue type face and DTE’s responses are labeled as such. 

Detailed feedback is provided in the attached document.