IPWG: FERC Order 2222 (20210525)

Transmission Owner Sector Feedback on FERC Order 2222

June 15, 2021

In the May 25, 2021 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback regarding MISO’s Conceptual Framework for interconnection of studies that are needed in the implementation of FERC Order 2222, and any additional questions regarding the  Order.  The Transmission Owners Sector appreciates the opportunity to comment and provides the feedback below for MISO’s consideration.

1)      It should be clearly stated in the Conceptual Framework that the EDC has the sole jurisdiction to approve these distribution level requests.  Regardless of Order 2222, EDCs must coordinate with the local TO to evaluate the potential for distribution-interconnected resources to inject power onto the transmission system.  However, once EDC and TO studies determine that there is a potential for backfeed onto transmission, and the Transmission Owner has notified MISO of that potential, it is MISO that must evaluate whether an affected system study is necessary and if it so, study the impacts of the potential injection.  The presentation appears to suggest (on slide 6) that the TO would perform the transmission system impact studies if they are needed, but under the Transmission Owners Agreement, MISO is the entity with the authority to assess the impact of injections on the transmission facilities of its Transmission Owning Members.  Additionally, it is assumed that these studies, like traditional Affected System Studies, would be performed using MISO’s models rather than Transmission Owner models, which do not include details regarding MISO’s neighboring transmission systems. 

2)      Any resources connected to the distribution system, independent of whether it is labeled as DER, LMR, BTMG, etc., that has potential for backfeed should always trigger an evaluation by MISO as relative to the potential impacts to the transmission system.  The Owners note that the need for an Affected System Study may be triggered by a single DER with the potential to inject onto the transmission system or by the total potential output of DERs participating in MISO’s wholesale markets behind a single EPNode (assuming that MISO establishes the EPNode at the Transmission/Distribution interface for DERaggregations).  Notably, this may change based on the composition of aggregation(s) behind that node, so Affected System Studies should be performed not only periodically, but also if the EDC has determined that the potential for reverse power flow has changed, based on DERaggregation participation at an individual EPNode, along with the total levels of Demand Response and DERs behind that EPNode.

DTE Energy appreciates this opportunity to provide feedback on MISO’s initial strawman for the interconnection of DERs under Order 2222.  DTE is supportive of several aspects of MISO’s proposal, particularly the deference to state-level processes for distribution-level interconnection as well as the identification of EDC interconnection approval as a prerequisite for wholesale aggregation registration.  There are other aspects of MISO’s proposal and the accompanying discussion which merit clarification, which are identified by page number in the discussion below.

Page 2

• MISO’s presentation states that DER Aggregators will connect through Relevant Electric Retail Rate Authority/state interconnection processes. 
  • However, distribution-level interconnections are granted to individual DERs, not aggregators. 
  • The aggregator may act as an agent or developer, but the interconnection is with individual distribution customer. 
  • MISO should be clear on this point in its documentation going forward. 
  • MISO’s presentation states that DER Aggregators will attest they have met all interconnection requirements upon registration for market access. 
    • However, it will be important for there to be a process to validate this attestation with the distribution utility prior to the approval of a registration as well as a process to remove, suspend, and audit registrations as interconnection configuration or ownership changes. 
    • DTE’s understanding is that this validation would take place during the aggregation review process rather than the interconnection process. 
    • MISO should clarify how the interconnection process and the aggregation review process relate to one another (DTE’s understanding is that these are separate processes) as this will clarify which activities belong in which process. 
      

 Page 4

• Regarding Box B, DTE notes that DERs (storage in particular) may also demand power from the distribution system rather than just injecting.  MISO should consider clarifying this graphic going forward. 
  

Page 6

• Further clarification is needed on what defines “Interconnection approved by EDC” in the final step of the process. 
  • There may be several levels of approval within a state’s interconnection process, such approval of an application to interconnect, approval of an interconnection’s design, or post-commissioning approval to operate. 
    • Even if a resource receives certain interim approvals, it may still not receive full approval to operate. 
    • For example, a resource may receive approval for its application and design but then fail to build properly or fail commissioning testing. 
    • In light of these potential scenarios, DTE recommends that “EDC approval” refer to the EDC’s approval to operate following the successful completion of testing and commissioning activities. 
      
      
• Again, DTE notes once a resource declares its intent to participate in an aggregation, additional review by the EDC may be required beyond the review conducted as part of the interconnection process. 
  • MISO should clarify how these processes relate to one another and that an approved interconnection does not confer approval for participation in an aggregation. 
  • DTE also notes that an interconnection may still require new infrastructure even if the project passes the relevant interconnection screens.
    • For example, new service equipment or a line extension may need to be installed as part of a new interconnection.
    • MISO should reflect this in its flow diagram by extending the “EDC requires system modifications” to the left to cover the other process flow path or by adding a separate box noting “EDC requires other modifications as necessary”.
      
      

• MISO’s process should include clear timelines for MISO and TOs to complete their interconnection studies and models.  
  • EDCs are ultimately accountable to their regulators in the on-time completion of studies required for interconnection, but the completion of studies beyond the control of the EDC (such as those which may be required by MISO or TOs) can have a material impact on the timeline for completing an interconnection. 
  • While MISO is proposing that DER interconnections would be processed separately from the Generator Interconnection Process, DTE’s experience with the GIP underscores the timeline challenges that can result when a wide range of entities need to be involved to process an interconnection without clear timelines and mechanisms to enforce those timelines (for example, while the GIP is intended to be a 500-day process, the actual time to complete the process can be more than double that)
  • Such variances in the time to complete the required studies will be nearly unworkable, particularly if this process needs to dovetail with state-level processes with firm timelines. 
  • As such, EDCs require clarity and accountability from MISO and TOs that studies will be completed on-time and model data will be delivered within expected timelines.
    
    

• MISO should also handle payment and invoicing for affected system studies with the individual DERs (rather than the EDC handling payment and invoicing DERs where MISO has identified the EDC as an affected system).  There should be a process for the EDC to provide an invoice for studies to MISO and the MISO handles the invoicing and payment of the interconnecting parties. 
  

Page 7

• MISO’s graphic on this page lacks a feedback loop from the MISO/TO level back to the EDC level, which appears inconsistent with the graphic on the previous page.  MISO should revise this graphic to be consistent with the graphic on the previous page. 
  
• MISO’s presentation stressed that the Generator Interconnection Process for transmission-connected resources will be separate from but parallel to the affected systems study processes that would be part of the DER interconnection process.  If distribution-level DER aggregations have a sufficiently significant impact on the transmission system, how will those impacts be reflected in GI process and DPP phases?  How will the separate but parallel processes be coordinated? 

Advanced Energy Management Alliance

MISO Interconnection Process Working Group (IPWG)

“FERC Order 2222 – MISO Proposal” Feedback

June 15, 2021

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Interconnection Process Working Group (“IPWG”) on the proposal for addressing Order 2222 implications to the MISO Interconnection Process as presented at the May 25, 2021, meeting of the IPWG. 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.

In the proposal from the May 24 IPWG, MISO presented a set of principles for DER aggregation interconnection, stating the following:

• “Electric Distribution Company (EDC) interconnection approval is a prerequisite for wholesale aggregation registration.”

• “DER or DER aggregations will not enter the MISO [interconnection] queue but would need to coordinated.” MISO proposed the need to establish a threshold for affected systems study, timing and frequency of those studies, and coordination of study assumptions and results.

Based upon the outline given by MISO staff and discussion within the IPWG, AEMA is supportive of the proposal made by MISO. The interconnection of a DER should be handled through the appropriate distribution level interconnection process, as stated by MISO. At no point should resources connecting at the Distribution level be required to enter the MISO Interconnection process and queue which is intended for Transmission level resources.

The purpose of FERC Order 2222 is to facilitate the participation of aggregations of already connected DER assets within wholesale markets, eliminating barriers to market participation. Given that DERs are already interconnected through appropriate processes within the EDC and/or RERRA, MISO should only be focused on confirming that the DERs followed the appropriate process. The aggregation of DERs is not a new asset connecting to the system but an aggregation of already interconnected assets. Therefore, AEMA believes that the proposal by MISO, to not be directly involved in the interconnection of DERs and to not require DERAs registering to participate in the market to follow MISO interconnection processes is reasonable, does not create additional barriers to participation, and meets the intent of FERC Order 2222.

As MISO begins examining the threshold for affected systems studies and the timing and frequency of those studies, we encourage MISO to set a reasonable threshold and set the frequency of the studies to no less than quarterly.  

AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed in both the DERTF and the IPWG. 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

Entergy Operating Company Feedback on Order 2222 Interconnection Requirements

June 15, 2021

In the May 25, 2021 meeting of the Interconnection Process Working Group (IPWG), MISO invited stakeholders to provide feedback on MISO’s Conceptual Framework for DER interconnection of studies  needed for the implementation of FERC Order 2222, along with any additional questions regarding the  Order.  The Entergy Operating Companies (Entergy) appreciates the opportunity to comment and provides the feedback below for MISO’s consideration.

Per MISO, a DER or DERa will not be required to enter the MISO queue, but their participation in MISO’s wholesale markets will require coordination, and MISO has requested input on the following aspects of this coordination:

1. Threshold for affected systems study
2. Timing and frequency of studies
3. Coordinating study assumptions and results

Each of these item is addressed in the feedback below.

1.  Threshold for affected systems study – Entergy agrees with MISO’s current practice of requiring Transmission Owners to notify MISO of the potential for any backfeed to the transmission system in order for MISO to determine whether an affected system study is needed.

• The 5MW “resource-size” trigger for a MISO affected system study being discussed is not appropriate.  Rather, as discussed further below, the threshold for MISO to determine whether an affected system study is needed should be based on the potential for injection on the transmission system via reverse power flow, either from a single resource or one or more aggregations behind a single EPNode, based on the results of an EDC study.   
• Entergy’s limit for Distribution Interconnection is a 20MW; interconnections above 5MW require a transmission evaluation to determine the need for an affected system study by MISO.

 2..  Timing and frequency of studies –

• An aggregation may result in an overall injection where DERs are also interconnected behind the EPNode where the DERa is registered, regardless of whether the DER(s) participate in MISO’s wholesale markets.  Wen such an injection has been determined by the EDC and/or Transmission Owner, a MISO affected system study may be necessary to determine the impact of the potential injection.  While it may be appropriate to “queue” aggregations for collective study, if an individual resource or aggregation is identified as having a potential to inject onto the transmission system the requirement to study these injections individually should continue to be managed as they are today, on an individual basis.    This information is important to MISO, the TO and the EDC  because the potential for backflow onto Transmission is an indicator that the capacity of the Distribution system behind that EPNode is at its limit, and plan accordingly, for example by recruiting additional Demand Response Resources or identifying the system upgrades that would be necessary to accommodate any additional DERs. 
• Regarding the study of a DER aggregation and differences in feeder loading capacity, MISO must consider using the EDCs to conduct any impact study in which any aggregated load change a MW participation trigger (+/-200kVa is recommended) at an EPNode must require a new evaluation/study.  Note: 200 KVA is based on the minimum reverse power required to create damage to Transmission equipment following a loss-of-power event.
• For all aggregations registered to that node in addition to a periodic evaluation of aggregations is also necessary because where an aggregation includes both DR and DERs, the level of DR will impact the potential for the DER(s) (both those participating in MISO’s wholesale markets and those that are not) to flow back to the transmission system.  The potential for reverse power flow will also change as the DERa changes the composition of the aggregation, so MISO will need to monitor the overall amount of participating aggregations at an EPNode and provide this information to the TO and the EDC so that the EDC can evaluate the potential impact of DRs and DERs participating in MISO’s wholesale market in conjunction with DERs and DRs participating in retail programs or not participating in any program at all. 
  • Additionally, IEEE requires periodic testing for generation interconnected at transmission; Entergy, for example, requires anything over 300kva to be tested every 5 years.  MSIO should also require period testing to evaluate the resource’s continued ability to provide the load reduction it is offering to provide to the MISO market(s). 
  • Entergy also requests clarification on how these studies will be paid for.

3.  Coordinating study assumptions and results

• Entergy supports the current process for injection resources, but as noted above, coordination will be required between MISO and the EDC for the EDC to communicate potential issues as they may arise due to a new DERa participant or changes in an existing aggregation.
• On Slide 6, it is not clear if MISO is intending to indicate that the Transmission Owner would do perform the affected system study, but this is not possible where the Transmission Owner has transferred control of the potentially impacted facilities to  MISO, and along with that, the sole authority to grant access to the transmission system.  MISO will need to perform these studies and evaluate whether transmission facility upgrades are needed.  It is assumed that these studies, like traditional Affected System Studies, would be performed using MISO’s models rather than Transmission Owner models, which do not include details regarding neighboring transmission systems. 
• Slide 8, for Distribution Interconnections, states “No coordination necessary if pass impact screens.”  As noted above in the response above relating to Timing and Frequency of Studies, continued coordination is needed to appropriately evaluate the impacts of DER aggregations and their potential to create reverse power flows at the Transmission/Distribution interface.

Response of Illinois Commerce Commission Staff to MISO IPWG Feedback Request

In the May 25 meeting of the MISO Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback and any additional questions regarding FERC Order 2222.   The Illinois Commerce Commission (ICC) Staff is offering the following feedback on MISO’s May 25, 2021 presentation on distributed energy resource aggregator (DERA) interconnection framework under Order 2222:

1. The MISO plan involves separating responsibilities for studying DERA interconnection impacts on the grid across three ascending hierarchical levels.  In this plan, the electric distribution company (EDC) has the first responsibility for assessing a DERA interconnection’s impact on the grid.[1]  If the DERA interconnection does produce effects, responsibility for further studies transfers upwards next to the transmission company and finally to MISO itself, if necessary.  In order to ensure the timely processing of the required interconnection studies, MISO should consider providing the EDCs with sufficient detail on what interconnection studies should entail.
2. The MISO plan could also benefit from more elaboration on the coordination between the EDC, the transmission operator, and MISO during the study and transmission upgrade process.  The DERA interconnection and upgrade process will hinge on clear, regular communication between these entities.  MISO should clarify whether it intends that the communication be formalized and standardized.  In particular, it seems possible that restructured states will face extra steps in this communication compared to states with only vertically integrated utilities.  The ICC Staff hopes these potential differences are taken under consideration. 
3. MISO should also ensure it that it understand the required visibility and relevant metering that will be necessary to make full use of DERAs.  For example, are all current EDC interconnection processes able to meet these requirements, and if not, how might these standards be brought into better alignment?

At their core, the ICC Staff’s concerns are about standardization of the DERA interconnection process.  In order to facilitate DERA interconnections, a clear and sensible process is necessary.