During the June 10, 2021 Market Subcommittee (MSC) meeting, MISO reviewed Order 2222 framework, progress, and new recommendations. MISO is requesting Stakeholder feedback on the following recommendations:
Please provide feedback by June 28.
DTE reiterates its previous feedback provided to MISO in response to the 4/12 feedback request to the DER Task Force, which is duplicated below.
DTE supports a maximum limit on the size of individual DERs participating in a DERa for the following reasons:
In conclusion, for the reasons listed above, DTE recommends a size limit reflecting the lower of 5 MW or any relevant limitations from state-level rules for individual DERs participating in a DERa. DTE believes that if the allowable scope of an aggregation continues to be at an EPNode level as MISO has proposed, then a maximum aggregation size may be less necessary than a maximum size for individual resources. However, if MISO were to expand the allowable scope beyond a single EPNode, this question would need to be revisited.
DTE would also like to stay close to the development and implementation progress of the optimization engine by MISO to allow 1 MW unit commitment. Many other ISO’s have expressed concerns and stayed away from unit commitment for DERa’s of any size. DTE would like to be cautious on the convergence challenges that may be introduced by allowing unit commitment optimization at a small size limit, particularly given other ISO’s considerations.
Xcel Energy appreciates the opportunity to provide feedback to the MSC regarding O2222 Recommendations:
Small DERa (<1 MW) must self-commit
Xcel Energy has no concerns regarding the proposal that DERas<1 MW must be self-committed as this balances the need to open the market to smaller DERas with the current capabilities of the optimization engine.
No size limit for individual DER within an aggregation
Xcel Energy recommends that the maximum size limit of 5 MW for DERs participating within a DERa. In markets with substantial interconnection activity, where there are many projects in a queue, it is important that the queue contains projects that have reasonable viability for interconnection success, especially in a fledging market. Maintaining efficient use of engineering resources to perform studies and assessment of remediation costs, with costs the demining factor for interconnection viability, can be critical in limiting queue backlog. An individual maximum limit of 5 MW for a DER within a DERa is consistent with maintaining DERa registration viability where such registration will require review of localized distribution company impacts of a large DER facility participating within the wholesale market. Both PJM and NE-ISO have made proposals to set the size limit of individual DERs at 5 MW participation in a DERa. MISO should consider adopting a similar proposal.
No size limit for DER aggregations in total
The current proposal to restrict aggregation to an EP node sets a natural limit on the size of the DERa so we do not believe MISO should set a DERa maximum size limit at this time. However, if aggregation is allowed to extend beyond the EP node level, this limit would need to be revisited.
During the June 10, 2021 Market Subcommittee (MSC) meeting, MISO reviewed Order 2222 framework, progress, and new recommendations.
Environmental Sector Response:
The Environmental Sector appreciates this opportunity to provide feedback on the below MSC recommendations.
Small DERa (<1 MW) must self-commit
The Environmental Sector does not oppose this recommendation. However, we are concerned that there has not been adequate discussion of the potential impacts this could have on DERA. We urge MISO to hold a DERA workshop to get more detail from potentially affected DERA on this and other issues.
No size limit for individual DER within an aggregation
The Environmental Sector agrees.
No size limit on DER aggregations in total
The Environmental Sector agrees.
MSC Feedback Request on Order 2222 – Due June 28
MSC: Order 2222 Recommendations (IR070) (20210610) (misoenergy.org)
During the June 10, 2021 Market Subcommittee (MSC) meeting, MISO reviewed Order 2222 framework, progress, and new recommendations. MISO is requesting Stakeholder feedback on the following recommendations:
Please provide feedback by June 28.
See OMS previous comments on this issue submitted to the DER TF.
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DER TF Compliance Iteration 1 Feedback Request - Due June 28
DERTF: Filing Framework Document – Iteration 1 (IR070) (20210607) (misoenergy.org)
During the June 7, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO presented Iteration 1 of FERC Order 2222 Filing Framework. Stakeholder feedback is requested on Filing Framework Document, DERa Resource Modeling, Settlements and dual participation. Focus should be on the following questions:
The Organization of MISO States’ Distributed Energy Resources Working Group (OMS DERWG) appreciates the opportunity to submit the following comments. This feedback does not represent the position of the OMS Board of Directors.
MSE Connection and Other Software Limitations
The OMS DER WG noted that additional transparency on how the Order 2222 compliance framework will be affected by, or will be advanced, in light of the Market System Enhancement timeline and in relation to the Order 841/ESR product timeline will be a useful addition to Compliance Iteration 2 and discussion at the RERRA workshop and August DER TF.
It would be useful for stakeholders to understand the MISO timeline for when certain MSE capabilities would be possible, what the timeline for Order 2222 compliance looks like, whether there will be a transition period or timing, what matters or issues are reliant on the MSE roll-out or whether they will be utilizing the legacy system.
Additionally, beyond the MSE, there was an ask at a previous DER TF for an overview of MISO software (including MSE but also other potential software or system limitations) and what those limitations are in relation to Order 2222. This OMS DER WG believe this discussion is important to understanding while we discuss Order 2222 methods to product development to understand what are the current and future bounds of MISO’s system. Additionally, points to address would be whether, and who, are working on further development of those software or system limitations, what is driving the development, and if possible, understanding of the timeline for the research and outcomes.
Iterative Order 2222 Tariff Development – Post April 2022
As it has been discussed, there are likely going to be improvement needed either from technological advancements, advanced market software, or other changes – and as acknowledged by FERC. The OMS DER WG would like to hear MISO discuss how it may address a change management and ‘relook’ at Order 2222 compliance in a conscientious manner (and likely) independent of the IR process post-April 2022 - and how that discussion and timeline may be built in as a feature of the Order 2222 compliance filing. The OMS DER WG has concerns that MISO funding or IT barriers will restrict future improvements of the Order 2222-tariff, and therefore, may limit its success. It is known that this filing is leading tech, and that we expect there to be significant change (both in our understanding, how we utilize the market products) and therefore a proactive plan to revisit the compliance framework in the future should be a built-in feature of compliance.
Connection to MISO Hybrid Work and Workshops
The OMS DER WG sees multiple areas of overlap between the DER TF and the on-going hybrid resource work. The OMS DER WG wants to ensure that any similarities, connections, or streamlining of resource and product development be mimicked wherever possible to ensure efficient and less complex solutions (and market products).
Roles and Responsibilities
The OMS DER WG sees the MISO slide defining potential stakeholder or industry sectors as needing discussion and improvement. MISO should consider stakeholder input on how to define these roles and responsibilities; this may be an area where stakeholders bring to the table their proposed definition and roles within the process for collective DER TF input. Additionally, the OMS DER WG wants to ensure that any roles or responsibilities that are defined in an Order 2222 compliance be vetted by that stakeholder sector and be as minimal as possible.
Interconnection Process
The OMS DER WG is appreciative of the work underway in the Interconnection Process WG on the process for DERas to be evaluated and the timing and quarterly review process MISO has proposed. The OMS DER WG recommends MISO ensure that a similar and transparent process also be developed for DERs and affected system studies (not just DERas).
Use of Single EPNode
As noted in previous comments, the OMS DER WG understands that use of the EPNode may be reasonable for the first iteration of compliance, but MISO should consider if there are varying aggregation levels that could be used for different market products. Additionally, MISO should continue to evaluate and research solutions to obtain a broader than EPNode aggregation geographic scope. OMS DER WG continues to supports its earlier comments, and seeks MISO to return with periodic updates on the progress and needs to support a broader than EPNode options, even post-Order 2222 compliance filing.
Metering and Telemetry
The OMS DER WG find the metering and telemetry issue to be complex and will require considerable stakeholder discussion. As FERC seeks, M&T requirements should rely on distribution or utility metering requirements where ever possible. As MISO is aware, those requirements could vary by program, utility, or state. MISO should delineate what are the base needs for metering and telemetry so that state regulators and utilities can consider wholesale M&T needs in future decisions and approvals.
M&T requirements should be as minimal as possible, providing MISO with the data it needs for registration, operations, and settlements etc. but avoiding undue burdens. As such, available or existing M&T systems should be used where ever possible.
As to other questions posed by MISO, the OMS DER WG may provide further comments or input following review of other stakeholder comments.
In response to MISO’s questions concerning requirements for aggregations and self-commitment under FERC Order 2222 as presented in the June 10, 2021 MSC meeting, the Entergy Operating Companies ("EOCs")[1] restate previous comments provided in the DERTF, and continue to support MISO’s proposal that provided that the aggregations will occur at a single EP Node, MISO should not limit the size of an individual DER within an aggregation and that MISO should not limit the size of a DER aggregation in total, though EDC DER interconnection standards may include such limits or may require different studies to be performed depending on the size of the resource and where it is seeking to interconnect. Additionally, the EOCs continue to support self commitment for DERas less than 1MW in size. For clarity, below are additional details in the context of the EOCs original comments referenced above.
Each distribution utility, not MISO, should have the ability to specify its own maximum size limit for a single DER based on reliability concerns, physical limits, interconnection requirements of its system and to allow compliance with any rules/limits promulgated by regulators that the EDCs are subject to. Currently, on the Entergy Operating Companies distribution systems, 20 MWAC is the upper bound for resources interconnecting on distribution facilities (35kV and below).
One thing that will need to be considered is how should distribution system capacity for DERs be allocated? While this issue should be decided by the state regulators and retail service providers, it is worth mentioning now and is something all should be giving thought to.
Assuming that DER Aggregations are to be made at a single EPNode, as currently proposed by MISO, then there should be no need for MISO to limit the size of the DER Aggregation. However, if it were decided that a DER Aggregation could occur on a geographic scale greater that a single EPNode, then this topic would need to be revisited.
It is also worth noting distribution systems commonly contain the ability to manually or automatically shift customers between different substations. While generally less common and typically driven by maintenance or outages, this temporary topology change can result in the resource shifting to a different EP Node and MISO should consider how this may impact its intended cost structure including, e.g., the necessary communication systems for the EDC to communicate any changes in configuration of the distribution system in real time to the MISO and the DERA. Size limitations are considered on a local basis by the distribution utility.
As stated in item one above, interconnection requirements, physical limits and regulatory requirements would end up driving any limits placed on the size of the DER Aggregation.
Given current and near term limitations related to optimization and commitment engines, the EOCs agree that, for now, DERas less that 1MW in size be required to self commit. As MISO has stated, we would agree that futher enhancements should be explored once “2222 compliance is achieved and implemented”. This would allow additional market efficiencies to be realized.
One area of concern would be the potential lack of make whole payments for self committed resources. To this end, MISO needs to be clear and educate participants as to this subject.
The EOCs appreciate the opportunity to provide input.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
It is logical given MISO’s current technical limitations to require self-commitment from resources that are <1 MW. That said, current--and, one would hope, temporary--technical limitations should not be the primary driver of policy decisions. Tariff updates to implement 2222 should require self-commitment of small DERAs in the near term (2 years?) but explicitly note that this requirement is a temporary workaround that will be removed when system upgrades are implemented. Such system upgrades should be scoped and funded.
Voltus agrees that neither individual DERs nor DER aggregations should face size limits.
During the June 10, 2021 Market Subcommittee (MSC) meeting, MISO reviewed Order 2222 framework, progress, and new recommendations. MISO is requesting Stakeholder feedback on the following recommendations:
While MISO has not requested input at this time on telemetry, ITC offers the comments below to supplement those we have previously submitted on this technical issue.
ITC submits these comments to supplement the comments we have previously submitted. These comments are particularly important given the work group/MISO recommendation on the potential for no limit to DERa size, potential element for no limit to DERa component size, and the self-commitment for DERas under 1 MW.
ITC supports a telemetry requirement consistent with that of other resource operators –that between a 2 and 10 second scan rate--be required for DERas. These are in addition to the other comments we filed on IR070. The basis for this recommendation is:
1) Order 2222 provides for the participation of distribution-level resource aggregations at the wholesale-market level. The use of distribution-level resources to serve demand will, all other things being equal, displace output of resources interconnected at the Bulk Electric System (BES) level. As DER aggregations are dispatched to serve load, they will displace resources managed by Generator Operators with NERC level compliance obligations or guidelines. Thus, the performance and visibility of DERa resources for capacity and energy should be on par with the performance expected of resources at the BES level. Said another way, to the extent that DERas may or may not be able to provide the same services or have the same performance requirements as BES level resources, or to the extent that they provide improved services, MISO may want to expand or modify performance rules and/or market-based grid reliability services to be able to manage the BES under increasingly complex scenarios. To this end, telemetry scan rates for DERas should be 10 seconds or less, or consistent with the scan rates required for generators in each LBA/TOP zone. Such scan rates are necessary for MISO and TOP visibility into the operation and reliability of the system.
2) As we have noted verbally at the DERTF meeting on 6/7/21, and the MSC on 6/10/21, and in our comments above, one might reasonably anticipate that the preponderance of DER aggregations will be in urban centers—precisely because there is more load there that could respond. This creates potential issues arising from the concentration of these resources –such as modification of flow patterns on the distribution and potentially the bulk electric transmission system that were not anticipated when the systems were designed. A telemetry scan rate of two-to ten-seconds will facilitate operational awareness and help MISO systems and operators function with the most current information, similar to how MISO monitors the performance of other resources.
3) Any DERa or DERa component that is able to provide >= 5 MW at a single location should be telemetered to the aggregator. This expands on our comments above by suggesting that sub-aggregation level telemetry should be required for resources above a certain MW threshold. At some point, MISO may need such data from the aggregator--particularly if significant concentrations of resources are present and operating in a small geographic area. Moreover, establishing such a requirement at the outset will facilitate more accurate dispatch and facilitate documentation of resource response. Such a requirement is consistent with MISO BPM-002 that requires resources greater than 5 MW be modeled.[1] As there may be an incentive to connect multiple resources under the modeling threshold level, MISO, through the registration process, may want to monitor the number of resources close to the threshold level to see if lowering the modeling threshold requirement is necessary.
4) From a market efficiency standpoint, the dispatch of Regulation and Responsive reserve from other resources, as well as Ramp calculations, could be impacted by a scan rate slower than the 2-10 second rate for DER aggregations because a slower scan rate would introduce an additional uncertainty parameter (output of the DER aggregations) that would need to be estimated and included in the state estimator and dispatch algorithm calculations. In particular, regulation service where resources receive a pulse vey four seconds runs at a faster rate than the 30 second scan rate MISO is evaluating. These ancillary services are important for the reliable operation of the BES. MISO already requires similar telemetry from DRR Type II resources and we recommend that consideration be given to applying these requirements to DERas. As noted earlier, every wholesale dispatch instruction to a DERa supplants a dispatch instruction to a resource interconnected at the BES level. Thus, again, the visibility, performance and control of DERa resources is important to the secure operation of the BES.
5) MISO has multiple tools comprised (in part or in whole) of Demand Response Resources. Presently Load Modifying Resources, LMRs, resources are not dispatched until a Max Gen Emergency Step 2a or higher. Specifically, “If MISO does NOT declare a Max Gen Emergency Event Step 2a or higher at least two hours prior to the start of the Scheduling Instructions issued in anticipation, the LMRs are NOT obligated to perform.”[2] The choice not to dispatch LMRs until this step in the emergency sequence arguably makes these resources as important if not more important than other resource types on the MISO system—because they are dispatched only close to a ‘last resort.’ While this does not place the burden on the LMRs to be available all the time, they are required to be available for dispatch in dire Capacity Emergencies. Thus, the scan rate should be on par with other BES resources. To date, nothing would preclude an LMR from being part of a DERa. However, we suggest that this be clarified and/or tracked in registration to avoid double counting as we note above.
As previously provided in feedback to the DERFT re MISO’s compliance with Order 2222, WPPI supports the following MISO recommendations: small Distributed Energy Resource aggregation (<1 MW) must self-commit, no size limit on an individual DER in an aggregation, and no size limit on a DER aggregation in total.