DERTF: Use Case Studies (IR070) (20211101)

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – USE CASE STUDIES
DATE: NOVEMBER 15, 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 use case studies.

Use Case Studies

• In response to MISO’s question regarding the intended goal of a post Oder 2222 Implementation study detailing the impacts of DER participation on current energy and ancillary services carried by the system, the EOCs suggest exploration of the following:
  • As with other market enhancements, it would be prudent to validate and review the outcomes of implementing Order 2222 over time.  This would help to provide insight to and measurement of the various benefits and impacts realized under the Order, which could also be used to inform the need for any additional changes post implementation.
  • In addition to the above, due to the potential impact to distribution systems posed by the aggregation of individual DERs acting in concert in response to MISO market dispatch, there could be unforeseen issues that need to be addressed.

The EOCs appreciate the opportunity to comment.

Please see email attachment for full feedback.

The OMS DERWG appreciates the work to date on use cases and continues to encourage further development on these examples. Additionally, the OMS DERWG appreciates examples where wholesale and retail DER are utilized to work through examples where double counting could occur and need to be addressed by both MISO and RERRAs. It would also be helpful for MISO to include examples of potential disputes that may arise under each use case to help stakeholders better understand potential issues, roles, and proposed resolution processes.

Xcel Energy provides the following feedback regarding the questions posed to EDCs on slide 13 of the Use Case presentation.   Data required by EDC is dependent upon location and size so information required may be determined at the time of the EDC review within the enrollment process.

Consumers Energy appreciates the opportunity to provide feedback regarding MISO's new Use Case examples.

CE generally supports WPPI's feedback.

CE generally limits program participation at the retail level by meter.

MISO's example of multiple facilities with separate account numbers seems reasonable. If an 8 MW facility is not being allowed to participate due to prior participation in a retail arrangement, a similar arrangement of perhaps 100 15 kW homes within a 1500 kW aggregation participating in a retail arrangement would also be a useful example of an ineligible participant.

CE takes exception to Use Case Ficus allowing residential batteries to be charged at LMP rate.

WPPI continues to be interested in the exploring the following aspects of the use cases:

(1.)  A use case in which only a subset of the distributed energy resources in an aggregation are also participating at retail. It seems a DER Group may also need to consist only of DERs that also participate at retail or do not participate at retail.

(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).

(3.)  Demonstrate how MISO will ensure the Electric Distribution Co.’s load purchases from MISO are accurately settled (i.e., hourly MW determined) under all types of DERs (including storage) making up a DERa.