DERTF: Use Case Studies (IR070) (20211004)

WPPI offers a couple of  comments on the use cases discussed at the 10/4/2021 DERTF meeting (which we agree help enhance our understanding of the many elements of O2x4):

(1.)  Given the potential implications of retail participation for wholesale participation, for each use case, it seems necessary to specify whether any of the DERs in the DERa (DER Aggregation) are participating at retail and, if so, how they are participating.

(2.)  When storage is involved in a DERa, demonstrate how will MISO ensure that withdrawals/purchases from the MISO energy market are injected/sold into the MISO energy market and not consumed at retail (in jurisdictions where DERa purchases at wholesale are not permitted to be used at retail).

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK - USE CASE STUDIES
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 use case studies. 

Use case examples and considerations 

• The EOC’s appreciate and support the development of use cases and think that they will be instrumental in understanding and addressing needed changes and processes. 
• When creating and stepping through use cases, the EOC’s think the following parameters should also be considered and explored:
  • Market design and registration should be in accordance with the Electric Distribution Company (EDC) interconnection process.
  • Settlements should be verified by EDC metering requirements.
  • MISO previously agreed that: (i) individual DR meter data is needed to implement Order 745; and (ii) M&V will be performed at individual DER level and rolled up to aggregation level; MISO has stated that DR customer baseline methodologies need review for adaptability purposes; MISO also has selected a “Meter Before / Meter After” approach for DRRs providing reserve products; and MISO has indicated that DR resources can be grouped into a homogenous DER resource within a heterogeneous DER aggregation.  Use cases that provide for a “grouped DR resource” within an aggregation should be developed and, among other things, should address: (a) who should own and pay for the grouped DR resource meter, and (b) why a “Meter Before / Meter After” approach cannot be used for all products provided by heterogenous DER aggregations with DR resources.
  • Use cases exploring Distributed Energy Resource aggregations (DERas) registered under utility tariffs should also be explored to fully vette market eligibility and identify potential double counting.
  • Details surrounding the impacts to current energy and ancillary services carried by the system as a result of Distributed Energy Resource (DER) participation should be explored
  • Reliability should be currently based on power quality standards and may need to be enhanced once Order 2222 is implemented. 

The EOCs appreciate the opportunity to comment.

Solarize Indiana, Inc. (SI) very much appreciates the opportunity to participate in the MISO DERs Task Force, which has proven to be most informative, encouraging, and stimulative in too many ways to enumerate here.  However, SI especially appreciates the work which MISO has done to develop and present for feedback illustrative Use Cases because they resonate so strongly "where the rubber meets the road," i.e. with the ultimate end-users of the distribution system who perceive the momentous opportunity presented both to inject and to withdraw from the system in ways and means that benefit both the participating end-users and the electric system as a whole. 

In that context, SI would once again enthusiastically endorse MISO's further development of Use Case Chestnut, which combines what our experience at the grass-roots level teaches us represents the most resonant chords with the smallest home, business, and non-profit based end-users, namely distributed individual solar facilities and distributed community solar facilities which can be aggregated with storage to form dispatchable "virtual power plants" for the benefit of both the participating end-users and the electric system as a whole.  SI also encourages further development of the MISO concept of the "home" and the "building" as locations for both injecting and withdrawing resources which can be aggregated in different ways for different purposes, "smart" HVAC thermostats and water heaters to become "dispatchable" load management resources of benefit to both the participating end-users and the electric system as a whole.

Moreover, SI would urge MISO to think about the wholesale-retail distinction not as a problem but as an opportunity to "pair" particular DERs for the benefit of both the wholesale (transmission) and the retail (distribution) electric system in a synergistic manner.  In that respect, SI believes it makes the most sense to think most and first about the DERs technology and metrology and then worry about jurisdiction as largely an after-the-fact accounting and settlements matter.  Most importantly, SI would urge MISO to think about DERs as inherently competitive products and services which will not only represent important innovation in their initial iterations but stimulate even more dramatic innovation in their subsequent iterations.  

In that regard, SI would urge the States, RERRAs and Distribution Companies to ponder long and hard the systemic potential of state-level Distribution System Operators (DSO) as an institutional mechanism with the same potential and the distribution-sytem level that ISOs and RTOs have proved to have at the transmission-system level.

Thank you for your consideration of these comments.

Michael A. Mullett, Advocacy Team Lead, Solarize Indiana, Inc.

CE supports ongoing MISO Use Case development and looks forward to further exploration and discussion related to market design, registrations and settlements, operations and reliability and DERa offers and related coordination.