IPWG: FERC Order 2222 (20210713)

Clean Grid Alliance Comments to the IPWG on FERC Order 2222
August 3, 2021

Clean Grid Alliance appreciates the opportunity to provide comments on MISO’s anticipated compliance plan for Order 2222. We believe it is of critical importance that MISO clearly outline within its compliance plan how queue priority is established in regard to impacts to the transmission system (and Network Upgrades) from the distribution connected projects. There will be impacts. Establishing the relative “queue priority” for projects individually and/or in aggregate on the distribution system in relation to queued projects in MISO’s generation interconnection process is a very important element of MISO’s Order 2222 filing. 

Projects on the distribution system and on the transmission system need to know where they stand relative to each other in regard to constraints they combined contribute to, or alone create on the transmission system. Additionally, there may be circumstances where proposed distribution connected and proposed transmission connected projects share Network Upgrade responsibilities. How cost is allocated for a shared Network Upgrade scenario is another critical aspect of coordination that clearly needs to be well understood and documented within MISO’s Order 2222 filing. MISO will also seemingly need to make and file concurrently changes to Attachment X to acknowledge this interaction and to address potential cost-sharing circumstances that might arise. Currently the MISO GIP has a process whereby Network Upgrades over $5M are to be shared with later queued projects in subsequent cycles up to 5 years out that benefit from these upgrades. Will this similarly apply to distribution connected projects that benefit from previously assigned Network Upgrades? Seemingly it must, else there will be a “free-rider” problem created. On the flip side of that, if policies are not clear, distribution connected projects could be unexpectedly/unpredictably assigned Network Upgrades that would create significant barriers. These projects need to know as early as possible what costs might be assigned to them. Transparency and fairness are key in creating policies that address the interaction between distribution and transmission connection projects in regard to Network Upgrades on the transmission system needed to accommodate DER and DERA participation.  

 We look forward to engaging in future discussions on this topic and appreciate MISO’s attention to incorporating clear policy around impacts to the transmission system, as this clarity will benefit both distribution and transmission level resources proposed for interconnection.  

Sincerely,

Rhonda R Peters, Ph.D.

Technical Consultant to Clean Grid Alliance

Otter Tail appreciates MISO seeking feedback as they develop their Order 2222 filing.  We specifically appreciate MISO seeking input on how to determine if DERa’s have impacts on the transmission system.  We agree with MISO in that there is no clear definition as to when MISO would need to perform studies. We also agree with MISO that the Transmission Owner is in the best position to determine if there are potential impacts to the transmission system. A single MW threshold may not be appropriate given different configurations and system topology.

Otter Tail supports MISO’s approach of studying DERs at least quarterly. Given the new study process, numerous details will need to be worked out. For example, if MISO proceeds with studying DERa impacts as a group, some type of cost allocation method will need to be developed for the DERs in the same group study.  

DTE Energy appreciates this opportunity to provide feedback on MISO’s proposed process for the interconnection of DERs participating in a DER aggregation.  The comments below reflect DTE’s feedback on issues which remain unaddressed in MISO’s proposal as well as questions posed by MISO to stakeholders. 

Need for EDC validation of DER interconnection as a prerequisite for market participation

DTE reiterates its concern that there will need to be a process for EDCs to validate that DER interconnections meet all relevant requirements for participation in an aggregation.  As state and EDC interconnection rules have evolved, so too have the requirements applicable to individual DER interconnections.  As aggregation of DERs becomes more prevalent, state and EDC requirements may continue to evolve to account for the new ways in which DER owners will interact with the electric system. 

However, DER owners/aggregators may not be aware of the evolution of these requirements and may in good faith provide an incorrect attestation.  As such, some level of interconnection validation will be necessary, likely as part of the EDC’s review of an aggregation.

For example, a customer with behind-the-meter generation may have been interconnected many years ago under a different set of interconnection, metering, and telemetry requirements.  Knowing that they have already been interconnected, this customer may seek to participate in an aggregation and attest that they have been interconnected by their local utility.  However, the customer may not have the metering to allow the load serving entity to distinguish wholesale and retail transactions.  Additionally legacy interconnections may need to adopt new technology compliance such as IEEE1547-2018 to enable the desired functionality and comply with interoperability standards, furthermore the change in operational mode of the resource may be outside of what was originally studied for the interconnection and would be considered to be a material modification to how the interconnection operates.

Timelines for TO and MISO completion of interconnection studies and models

While the graphic underlying MISO’s proposal seems to suggest some form of quarterly cadence for the proposed study process, MISO’s proposal has not provided any indication of the timeline expectations for MISO and Transmission Owners.  DTE requests that MISO’s proposal address timeline expectations for all parties that will be participants in this process. 

Billing and invoicing for studies

If a DER does require an affected system study, then there should be a contractual relationship between the DER owner and MISO for purposes of completing the study.  The EDC has no control over the cost of the study nor does it have the right expertise to interpret the results of the study, so it would be more efficient for those interactions to be handled directly between the DER owner and MISO.  Placing the EDC in the role of invoicing the DER owner for MISO studies unfairly places risks on the EDC (and by extension the EDC’s customers) for events such as non-payment or late payment by the DER owner. 

If MISO is not interested in directly interfacing with the DER owner for purposes of study invoicing, then DTE requests that MISO develop a proposal for how it will complete studies without placing the aforementioned risks on the shoulders of EDCs and their customers.