During the November 1, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the systems that will likely be impacted by Order 2222. Stakeholder feedback is requested on the following:
Please provide feedback by December 13.
Advanced Energy Management Alliance
MISO Distributed Energy Resource Task Force (DERTF)
“FERC Order 2222 – Software Enhancements and Future Process (20211101)”
December 13, 2021
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 November 01, 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 November 1st meeting of the DERTF, MISO introduced the subject of potential Software System upgrades that may be needed for compliance to Order 2222. MISO staff stated that “Order 2222 requires significant adjustments to several MISO systems, both within and outside the MSE-related improvements (MISO System Enhancement Project).” AEMA recognizes that the scope and duration of those upgrades is still being developed as the conceptual design for compliance is being completed and appreciates MISO requesting feedback on the potential enhancements that will be necessary for implementation of 2222 as MISO prepares the conceptual design. AEMA offers the following feedback to the questions posed by MISO:
When modeling the upgrades needed to support full integration of DERs into the MISO market, MISO should not wait to include every aspect of 2222 compliance before allowing DERAs to register and participate in the market. For example, MISO is planning to create a new market participation model for DERAs. The implementation of this new model will likely require significant software changes to MISO systems; however, if a DERA is registering to participate in the market using an existing participation model, and meets the current requirements of that existing model, then MISO should allow the DERA to register and begin market participation without waiting for all software changes to be implemented. Allowing immediate access to the market through existing models allows MISO and market participants to gain experience with DERA participation and to take advantage of the resources for optimizing reliability and efficiency of the market. Distributed Energy Resources are connected to the system today that could potentially begin participating in the MISO market very quickly.
A delay in implementation of Order 2222 will create lost opportunity costs for customers that include reduced savings on transmission congestion, fewer resources to meet ancillary services needs, and fewer flexible resources for MISO to deploy in emergencies. For these reasons, MISO should not wait until the entirety of the potential software changes are completed to begin market participation of DEARs.
Another example of this issue is Energy Storage Resource participation in the MISO market, which is planned for Summer 2022. A DERA that is registering a homogenous aggregation of distribution level storage devices should have the opportunity to access the market utilizing the new Energy Storage Resource model as part of MISOs initial phase of compliance to Order 2222.
AEMA members represent large operators of Distributed Energy Resources and include companies that specialize in advanced energy management and technology services. Members of AEMA are active participants in ISO/RTO markets across the nation and the primary set of enhancements that will be necessary for these companies to comply with Order 2222 will be in adapting existing processes to interface with MISO and MISO’s operating procedures, once MISO has published the procedures. The software changes include but are not limited to configuration of the interface to the MISO Market Portal (Operations and Modeling), Telemetry Systems configuration (if needed), Customer Interface and Dispatch systems (as needed), and Settlement processes design. Procedural changes include registration and enrollment, communications and dispatch procedures, outage coordination, metering and verification, and settlements.
Once the MISO policies, procedures, and system interface protocols are developed, published, and approved, the corresponding changes at AEMA member companies will typically be (3) to (6) months and focus on adapting existing processes and systems to the specific requirements of MISO.
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
WPPI offers the following feedback on the questions posed by MISO re systems likely impacted by O2x4:
(1) What enhancements do stakeholders foresee for their policies, processes, and systems, based on known Order 2222 requirements?
WPPI is the wholesale supplier for 50 municipal utilities and 1 coop in WI, IA, and MI (members).
‒ WPPI members need to develop a process that checks whether an aggregation of DERs poses any issues that individually they did not.
‒ WPPI will need to obtain access to the necessary information from its members in order to perform the review of a Distributed Energy Aggregated Resource (DEAR) enrollment (and any modifications) that consists of a WPPI member’s retail customer(s).
(2) What is the required timeline for those enhancements?
Initially, WPPI expects the new processes to be relatively labor intensive with future enhancements dependent on experience and the volume of DEARs.
The slides in the summary presentation -- including the draft diagram of required data inputs and coordination with existing and new Market Participants, color coded by entity type -- are a great start to what is needed. Our biggest concern is how we control and measure the information. We would need to build these functions into our Meter Data Management system or some other system, which could take years to implement.
Iteration 5 In response to Feedback Request from 11/01/21 MISO DER Task Force
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.
What enhancements do stakeholders foresee for their policies, processes, and systems, based on known Order 2222 requirements? What is the required timeline for those enhancements? (Software enhancements and future processes)
DTE Response: We anticipate multiple changes to policies, processes, and systems based on known Order 2222 requirements. Investments will likely include additional staff to handle modeling, controls, and data management, as well as DERMS with market-integration functionality and a wholesale interface for DER. Additionally, we expect to set up a new team and a set of processes, tools and platforms to support the DEAR registration process and aggregation review. New systems, processes, and resources will be required to evaluate reliability impacts of DER operations in both day-ahead and real-time operations. New requirements related to billing and communications with DER owners and DER aggregators will result in further updates to customer support systems and processes. The scale and timing of these enhancements, as well as enhancements yet to be identified, will depend heavily on the final form of compliance filings and state regulations.
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – SOFTWARE ENHANCEMENTS
DATE: DECEMBER 13, 2021
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the November 1, 2021 Distributed Energy Resource Task Force (DERTF) meeting concerning FERC Order 2222 filing framework and the related topic of needed software enhancements.
Software Enhancements
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
The Organization of MISO States DER WG believes the discussion that prompted this question was intended to relate to software, hardware, and business systems – however, we do acknowledge that the question, as posted, asks for policy changes that may be needed. Necessary policy changes are an active question being discussed at OMS and any answer would be speculative at this point and likely up to each state to determine to what level they would like to pursue and enable these market products.
At this time, the OMS is discussing potential policy changes in multiple levels of regulation (state statutes or rules, Commission orders, utility operational policy, industry standards) related to interconnection, DERA registration, dispute resolution, retail tariffs, retail programs, double counting, customer and grid data sharing, integrated planning, distribution system planning and operational safety and reliability standards, among others.
With regard to coordination/registration coordination and dispute resolution, accurate information regarding the physical boundaries of EPNodes will be very useful to RERRAs, EDCs, and DERAs. Developing geospatial tools will clearly define the EPNode boundaries that individual DERs must reside in to be contained in a given DEAR. This data will also help EDCs and RERRAs resolve jurisdictional disputes where a DEAR straddles multiple EDC service territories, or situations where a DEAR located near a neighboring EDC might cause safety, reliability, or operational challenges.
MISO should seek to minimize implementation delays due to software enhancements. MISO is moving forward with ESR in the first half of 2022 and so should be well equipped to resolve most software enhancement requirements no less than 12 months after Order 2222 compliance.