IPWG: FERC Order 2222 MISO Proposal (20210921)

ITC appreciates the opportunity to submit feedback on the FERC Order 2222 version 3 proposal and has the following comments:

For either MISO or the TO to determine the effect of DER connected and utilized in the MISO market through an Aggregator, the Aggregator will need to provide as part of its application package to MISO specific information on the DER units that comprise its aggregation.  From this information, either MISO or the TO will be able to update their models and perform either a Planning, Protection, or Operations level study on these DER units.  As an aggregator the information on what types of DER they are aggregating, and their characteristics should be paramount to their performance as an aggregator.  This is also the information we as system planners and operators will also need.  Requesting the data is not meant to place a barrier to them gaining access to the transmission system.  It is on par with requiring data for all other generators seeking to connect to the system, whether to the transmission system or the distribution system where the transmission system is an affected system.  TOs require data from the connecting generator Owners to evaluate any potential impacts.

DERa could cause:

• reverse power flow,  
• short circuit changes on the transmission system thus affecting protection relay settings and could over-duty protection equipment,
• could cause issues with protection configuration philosophies.

Please consider the need for specific information from the DERa for all studies necessary to analyze the performance of the system both in the Planning and Operating space.

Transmission Owners Sector Comments on FERC Order 2222 MISO Proposal

October 12, 2021.

The MISO Transmission Owners Sector provides the following feedback on MISO's initial responses to questions and provide additional comments regarding FERC Order 2222 version 3 proposal, as requested at the September 21, 2021 Interconnection Process Working Group (IPWG) meeting.

Regarding the review period provided for the EDC and potentially the relevant Transmission Owner to evaluate a DERa, the Owners note that this review will depend on the resources included in the aggregation, and 60 days may not be sufficient to cover facilities studies.  The Owners understand that Order 2222 requires that, "[s]ny distribution utility review must be completed within a limited, but reasonable amount of time. We expect a reasonable amount of time may vary among RTO/ISOs but should not exceed 60 days."  Facilities Studies can take 90-120 days to complete after feasibility and SIS studies, and thus should not be included in the technical review component of the registration process, as it is not clear how this aspect of the evaluation can be accomplished within the 60 days that the Order requires.

The Owners thank MISO for the opportunity to comment and look forward to continued discussion with MISO on this topic.

Clean Grid Alliance Comments on FERC Order 2222 MISO Proposal
Oct 12, 2021 

Clean Grid Alliance appreciates the opportunity to provide comments to MISO on its FERC Order 2222 Proposal presented to the IPWG in September. We believe MISO is heading down a path that will lead to significant problems and issues for DERs, DERAs and MISO Interconnection Customers in the future by not having solid procedures in place prior to the April 2022 filing to handle the interaction of DERs and DERAs with the transmission system in their interconnection process on the distribution system. The path MISO is going down will lead to problems for projects seeking interconnection on both the transmission and distribution system. In particular, the proposal to combine all DER/DERAs seeking distribution interconnection and look at that combined impact quarterly is setting up the conditions for significant impacts projects seeking interconnection and we strongly recommend that MISO adjust the approach and shore it up as one of the most critical tasks needed PRIOR to Order 2222 compliance filing in April 2022. 

 We recommend that MISO revise its proposal for quarterly studies of aggregated impacts to the transmission system and set up ENGINEERING METRICS to check for impacts that are built into the distribution interconnection process. For example, whenever flows up to the transmission system reach 90% of the rating of any element under the standard NERC contingencies they should be flagged/monitored and if they exceed 100% of the line rating, they should be studied by MISO. This is just one suggested example to explore. 

Additionally, since distribution interconnections are proposed to be studied as affected systems to the MISO DPP studies, a very clear system of queue priority MUST be established prior to Order 2222 Compliance. This clarity is essential for DER, DERAs and queued transmission level proposed interconnection projects so developers on each side can understand their queue priority relative to each other and which entity might first be assigned a Network Upgrade on the transmission system, amongst multiple parties in different study processes contributing to it. 

MISO should also consider the SNU—Shared Network Upgrade process and how that might work when that “sharing” occurs between distribution and transmission projects. 

MISO need only look at its current affected systems process to see how significantly the issues raised in these comments of timing and queue priority impact seams projects seeking interconnection within MISO and on seams external to MISO, to apply lessons learned from that to this “new frontier” of seams between the distribution and transmission systems within MISO. 

Sincerely,

Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Interconnection Process Working Group (“IPWG”) on the feedback request made by MISO at the September 21, 2021, meeting of the IPWG.[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 September 21 meeting of the IPWG, MISO presented their recommended interconnection and Distributed Energy Resource aggregation (DERa) review framework to stakeholders. As part of that presentation, MISO requested general feedback on the overall framework and specific feedback on certain aspects of the proposal. AEMA generally supports the framework that MISO has proposed and would request MISO to consider the following.

• MISO has stated that DER Interconnection and DERa review are two distinct processes whereby the DER interconnection is handled through the RERRA/state processes. MISO has also stated that a Distributed Energy Resource Aggregator (DERA) seeking to register for market access will not go through the MISO interconnection process but will attest that they have met all DER interconnection requirements. 

While AEMA agrees with the overall concept, an Aggregator that is aggregating existing DER should not be expected to determine if each individual DER has met all aspects of DER interconnection. Prior to DERa registration, the DERs have already interconnected and the DERA may not be privy to the historical aspects of that resource. It is reasonable that the DERA attest that the DERa has met all the interconnection and review requirements for the overall aggregation. During the registration review by the Distribution Utility, the utility should identify any DERs that have not completed interconnection agreements. AEMA believes this should be clarified in MISOs proposal.

• MISO requested feedback on “the applicability and utilization levels for a cost-sharing arrangement between GIP and DERa review (e.g., Attachment X).”

FERC Order 2222 has directed MISO to remove barriers to participation for DER aggregations. The implementation of cost arrangements for DERa review of a similar nature to the GIP, which can easily reach hundreds of thousands of dollars would be a major barrier to participation with no relevant benefit. The GIP examines the transmission system upgrades needed to connect a new or upgraded generator to the transmission system; however, when a DERA registers to aggregate a set of DERs, those DERs will have already paid for any of the system upgrades required by the utility when they interconnected. The DERs are already interconnected, there should be no need for significant study by MISO or the TO. The owner of the DER has already paid for the studies to interconnect to the system. While AEMA recognizes the need to examine any safety or reliability issues created by the aggregation of these DERs, this review should not be modeled after the System Impact Study of the Generator Interconnect Process (GIP), which is costly and time consuming. MISO could establish a threshold below which minimal examination is needed. AEMA suggests the following:

1. Any DERa that does not have the capability of injecting into the transmission system does not need a detailed review.
2. Any DERa that is does not have the capability to inject more than 20 MW into the transmission system does not need a detailed review.
3. A DERa that has the potential to inject more than 20 MW should have a more detailed review but not at the level of the GIP system impact study. 

• MISO requested feedback on how the determination would be made for a MISO-level review of the DERa. MISO has suggested two options: the TO performs the initial review and decides whether a MISO review is needed or the TO uses default thresholds developed by MISO. AEMA strongly recommends that MISO work to create a fair and balanced approach within the MISO Tariff. Leaving the decision to the discretion of the TO invites unfair opportunities. MISO should establish default thresholds (at a minimum) for determining when a MISO review is needed. MISO has suggested several options for thresholds and AEMA would recommend setting a DERa maximum power injection onto the transmission system as the threshold. A recommended amount would be a 20 MW injection; however, the Transmission Owner should have the authority to waive the MISO review threshold of 20 MW if the TO determines that one is not needed. 

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