DERTF: Resource Type and Bidding Parameters (IR070) (20211004)

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK - RESOURCE TYPE & BIDDING PARAMETERS
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 topics of resource participation type and bidding parameters. 

• Resource type and bidding parameters
  • Creating a single new resource type for compliance with Order 2222. 

• The EOCs think that a Distributed Energy Resource (DER)/Distributed Energy Resource aggregation (DERa) should have the choice to participate under one of the current resource types, if qualified, or under the as proposed resource type utilizing Electric Storage Resource (ESR) functionality that would allow participation by DERas as small as 0.1 MW.  We would agree that this new resource type based on the ESR model would offer the flexibility that may be required by heterogenous aggregations. 

• Clarity and appropriateness of bidding parameters and commitment modes 

• The proposed commitment modes appear appropriate.  While the self commit requirement that would be associated with the new DERa resource type is not optimal, current modeling and dispatch system limitations coupled with a potentially small aggregation make this an appropriate first step.  However, MISO should revisit this topic once operational experience is gained soon after implementation or Order 2222.   
• The offer parameter limits proposed by MISO appear to be in line with current offer limit parameters adapted for use with this new resource type and environment.  However, the DERa dispatch limits for withdraw and injection will need to be within the established operational range as specified in the Electric Distribution Company (EDC) interconnection agreement.  It would be helpful for MISO to present an example of what an offer might look like in a graphic form that would including meets and bounds.  

The EOCs appreciate the opportunity to comment.

Xcel Energy is supportive of leveraging MISO's ESR market participation model to develop a DERa participation model. Will the DERa participation model  follow the same requirements for transmission service that apply to ESRs?

Consumers Energy supports MISO creation of a single new resource type for compliance with Order 2222. Clarity and appropriateness of bidding parameters and commitment modes require additional review and discussion to define communication and coordination pathways and timelines for bidding commitments and communication between various parties including MISO, TO, DO, DERA, DER Group, DER and/or RERRA as necessary to define market requirements and equitable settlement.  

The OMS DER WG discussed concerns with self-commitment not providing DERAs the ability to manage their economic position both at wholesale and retail. While this may be useful as a short-term solution, if there are technological or other barriers on MISO’s system or software in managing economically dispatched DERAs, addressing these barriers should be a short-term to medium-term goal. MISO should work with DERAs on this issue to determine whether this is a barrier to a robust and workable market product.

MISO should supplement the slide deck on this issue with the basis for this decision, the OMS DER WG had a hard time recalling the justification behind this decision and could not find it easily in the materials.

This is another area where a matrix of other resource type's ability to self-commit or economic dispatch (and the basis for their ability to do either) would be useful to be outlined so stakeholders can understand how MISO is evenly applying these parameters.

WPPI offers the following feedback on the requested items:

(1.)  Creating a single new resource type for compliance with Order 2222.

• Previously, MISO proposed modifying as needed two existing resource types, Electric Storage Resource and Dispatchable Intermittent Resource, to accommodate the 0.1 MW minimum required by O2x4. At the 10/10/2021 DERTF meeting, MISO proposed instead to create a new DERa resource type leveraging the ESR resource type structure at 0.1 MW. WPPI leaves it to future DERAs to weigh in with their preferences regarding whether MISO’s previous or latest proposal.

(2.)  Clarity and appropriateness of bidding parameters and commitment modes

• WPPI also leaves this feedback item to future DERAs.

Advanced Energy Management Alliance

MISO Distributed Energy Resource Task Force (DERTF)

“FERC Order 2222 – MISO Compliance Framework Iteration 4 (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 Iteration 4 of the Compliance Filing Framework for compliance with FERC Order 2222. In that presentation, MISO requested feedback on their proposal for Resource Type and Bidding Parameters. In the recommendation, MISO proposes to create a “new DERa resource type utilizing ESR functionality at 0.1 MW.” MISO proposed multiple Commitment Modes associated with the new DERa resource type that is similar to the Electric Storage Resource (ESR). AEMA fully supports the decision to create a new DERa resource type. AEMA also supports the commitment modes identified by MISO and recognizes that in some instances, the resource may desire to operate as a “must run” resource. The option for a commit status of “continuous” is an important feature for aggregated resources to be dispatched smoothly from injection to withdrawal. 

However, MISO should not require the resource to operate in “must run” status. Much like generating resources participating in the MISO market today, the DERA should have the option to select either “must run” or “economic” commit status. Previously, MISO proposed “must run” for resources below 1 MW, which is acceptable because of the mechanics of the MISO clearing engine. Forcing a resource to always utilize “must run” creates operational risk for market participants and prevents clearing for full economic benefit. This restriction is not comparable to treatment of generators in the MISO market today. For example, a DERa could be comprised of multiple small generation resources which should have the option of full economic commitment status and the associated benefits of being economically committed. 

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 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 FERC Order 2222 Iteration 4 Presentations, accessed 10/11/2021.

• Slide 31: Pertaining to MISO’s DER Taxonomy, the MI PSC Staff is inquiring if MISO has considered the possibility of Energy Storage Resources (ESRs) also under the category, Behind the meter generation (btmg and BTMG).  We are thinking btmg and BTMG customers could both potentially have ESRs. 
• Slide 37: Pertaining to the new DERa resource type utilizing ESR functionality, the MI PSC Staff would like clarification from MISO on how they will manage the state of charge of the aggregator or resource owner?
• Slide 38: Pertaining to the time implementation of Orders 841 and 2222, along with the delays of the MSE, the MI PSC Staff is interested in MISO informing stakeholders of their modeling/activating of ESRs with the various states of charge since there is limited operation experience with 0.1 MW resources.  Do you envision delaying the implantation of these smaller ESRs for 2-4 years?
• Slide 23-2: (There are three slides labeled 23) Could MISO provide a definition of available?
• Slide 23-2: Regarding this new DERa Resource Type, is MISO envisioning that these could be old or brand new DERa type?
• Slide 23-2: How would a new DERa Resource Type become registered?
• Slide 41:  Could you provide an explanation or an example of how injection will occur into a ratepayer/customer’s system?
• Slide 53: Grid reliability all ties into the Bulk Electric System, and everyone needs to be on the same communication string especially during any outages:  Customer, Aggregator, EDC/LSE, LBA, MISO and TO.
• Slide 65: The MI PSC Staff supports all of this changes and as much as possible the requirements should be included in MISO’s Tariff, especially since the new DERa Resource Type could include the kitchen sink of grid enhancing technologies (GETS).  The more detailed MISO Tariff on metering, telemetry, measurement and verification, data submission, communications, timelines, and definitions, the better the implementation of Order 2222.
• Slide 79:  The MI PSC Staff supports the Aggregators forecast for DERa and again the communications between the Aggregators, Customers, EDC/LSEs, LBAs, MISO and TOs will need to be the same consistent email.  Everyone will need to know if the customer is injecting or withdrawing on an hourly basis.
• Slide 91:  Would it be possible to study DERa outages below 10 MW?  The issue that the MI PSC Staff could see is that every circuit is different, and 10 MW could be a massive issue on a smaller circuit.  With the new DERa Resource Type and MISO lumping in the kitchen sinks of GETS into this DERa, the communication string between MISO, TO, LBA, EDC/LSE, and customer with the Aggregator will need to be developed since everyone will be affected.
• Slide 94:  The MI PSC Staff disagrees with the “1 hour after DA before rebid closes”.  Currently one hour may be sufficient to review outages, identify and communicate DER system limitations since there are few DERa on the BES.  However, as more of these DERa resource types enter the BES and may affect more circuits across the MISO LBA footprint, we would support a 4-hour time frame for review.  The four-hour timeframe for review would be beneficial for the EDC to review the DA forecasts from aggregators.  If there are any discrepancies in the DA forecast, who should the EDC talk too; the aggregator or the customer? What happens if the aggregator wants injection and it affects another substation, does the TO need to be included in the communication string?  Who has the authority to overwrite the aggregator’s DA forecast if customer notifies the EDC of a different forecast?
• Slide 95:  The MI PSC Staff recognizes that in real time (RT) operations, the communication string amongst all parties is more important.
• Slide 99:  The big issue that the MI PSC Staff recognize for outages, is that the communication string between MISO, TO, LBA, EDC/LSE, aggregator, and the customer will need to be strong.  We all recognize that outages mainly occur on the distribution system, more so than the transmission system and thus when outages do occur, everyone affected needs to be notified immediately. Quick and clean dispatch orders and communications between all parties would be key.