DERTF: Management Plan Development (20220811)

Environmental Sector Comments on DERTF: Management Plan Development (20220811)

The Environmental Sector appreciates the opportunity to provide feedback on topics for consideration to be added to the management plan following up the August 11, 2022, meeting. During this meeting MISO communicated that it does not have the resources to devote the time and attention needed to be an active participant in DERTF, thus it has stated that for DERTF to continue the primary drivers must be MSIO Stakeholders, not MISO. 

Prior to this meeting the Environmental Sector summarized open items related to O2222 and DERs at MISO to facilitate discussion among stakeholders and consideration of priorities moving forward.      These items were captured in the former DERTF Chair’s March 18, 2022 “Memo to the Market Subcommittee” as well as in MISOs parking lot items (slides 141-143). These items were proposed by a diversity of stakeholders who see the DERTF as a productive space for identifying challenges and opportunities with an eye toward designing solutions. Inclusion of the items on the list did not necessarily indicate their endorsement by the Environmental Sector.      

During the meeting, stakeholders reminded MISO that the DERTF Charter includes much more than Order 2222 compliance as one aspect of its purpose. In order to help frame our recommendations regarding the DERTF Management Plan below, we first include the DERTF Mission Statement as found in the DERTF Charter, with non-2222 specific items highlighted in bold: 

DERTF Mission Statement: 

The purpose of the Distributed Energy Resources Task Force (DERTF) is to: 1) serve as a focused forum for stakeholders and MISO to address many cross-functional issues associated with MISO’s Order 2222 compliance as well as non-Order 2222 DER issues, 2) engage appropriate parties, including regulators, distribution utilities, and other subject matter experts in developing the coordination framework required by Order 2222, 3) identify potential risks and opportunities stemming from the integration and participation of DERs in the MISO markets, including study of the various services DERs can offer, and (4) recommend approaches and/or solutions to address these risks and opportunities to the Market Subcommittee (MSC).  

The DERTF reports to the Market Subcommittee (MSC) and will identify and track DER-specific issues that are within MISO’s purview and provide ongoing subject matter expertise regarding these issues through the appropriate MISO stakeholder processes and forums. The DERTF will provide a forum for development of IR070 Distributed Energy Resource – FERC Order 2222 Compliance      and other issues as delegated by the Market Subcommittee.

As can be seen from the above, three of the DERTF’s four main purposes directly relate to non-Order 2222 issues. Additionally, the second paragraph of this Mission Statement indicates the DERTF is to continue identifying and tracking DER-specific issues, not limited to Order 2222 compliance. As can be seen in the “Memo to the Market Subcommittee” and list of parking lot items, each identified above, there is still a wide range of non-Order 2222 topics appropriate for DERTF to focus on. 

Although we see value in discussing all of the issues included in our recent presentation, we      specifically recommend the following items be included in MISO’s DERTF Management Plan.

• MISO Updates on DER Topics discussed in other Stakeholder meetings. 
  • The DER “Affected Systems” interconnection process being developed at the IPWG.
  • DER Topics or issues impacting DER in other MISO Stakeholder Forums

• Development updates on the MISO roadmap leading to full implementation of Order 2222 as presented on Slide 5 in https://cdn.misoenergy.org/20220210%20DERTF%20Item%2004%20Software%20Enhancements%20and%20Implementation%20Timeline622791.pdf

• FERC Updates on the O2222 Filing. 
  • Updates to stakeholders on FERC decisions, requests for information, and MISO responses. FERC issued a request for information 8/12/22 on the MISO Order 2222 filing (available at: https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20220812-3036).  
  • Stakeholder review of MISO’s response to the Commission’s request for information and any new developments in the processes related to DER participation in MISO’s markets
  • The above request for information has a 30-day response window (with a 30-day extension requested by MISO). There appeared to be a strong consensus from stakeholders that moving the November DERTF meeting to late September would aid      MISO in developing a response to the FERC request by allowing stakeholders the opportunity to respond to proposed answers that MISO plans to include in its response to FERC. This would offer MISO to review and respond to feedback before filing at FERC, making any such filing stronger as a result. Accordingly, we request that MISO further advance the next DERTF meeting before the currently planned October 21 meeting date to such a date as would provide MISO with enough time to adequately consider stakeholder feedback on MISO’s proposed response to the FERC request before it files.  

• RERRA Updates on issues, concerns, assessment of processes related to O2222 at the state level. 
  • Given the division of responsibilities between MISO and the RERRAs on O2222, and the new roles and responsibilities RERRAs have, it is imperative that a public forum exist for communication and coordination between RERRAs and MISO. Prioritizing the DERTF has value for MISO in this coordination alone, let alone the many topics that fall under the DERTF jurisdiction. We strongly recommend a standing DERTF agenda item for RERRA presentations and new business/concerns. 

• Non-RERRA Stakeholder input in various DER and Order 2222 topics
  • Stakeholders have raised various issues such as IPPs not having access to modeling or even knowledge of where existing DERs are on the system, and putting them at a significant disadvantage over incumbent utilities who have full access to this information. Clean Grid Alliance has committed to making a presentation on this and is willing to do so at the next DERTF meeting. 
  • Role of DER and DEARs on Resource Adequacy in the MISO footprint –this topic was raised by stakeholders at the August 11^th DERTF meeting and warrants attention. Furthermore, FERC raised a number of points/questions on this in its request for additional information on the MISO O2222 filing. 

• Opportunities for DERs to provide services to MISO, including but not limited to the following:
  • Ancillary Services
  • Demand Response and Behind-the-Meter resource adequacy contributions
  • Congestion Relief
  • Application to VOLL, limiting load shed     

Submitted on behalf of the Environmental Sector.

Solarize Indiana (SI) appreciates the opportunity to submit this feedback with respect to Management Plan Development for the Distributed Energy Resources Task Force (DERTF) during its Sunset Extension Period (SEP).

With respect to the topics to be addressed during the SEP, SI generally agrees with the list compiled by the Environmental Sector.  However, SI is gravely concerned about the role and resources constraints which MISO staff disclosed during the August 11 DERTF meeting have been imposed by its governing body(ies) on its participation in Plan Development during the SEP.

First and foremost, neither MISO nor its Stakeholders have the luxury of delaying implementation of a fully compliant plan to implement Order 2222 until 2029-30: the urgency of the exigencies of the Climate Crisis confronting both MISO and its Stakeholders simply preclude such delay.  The rationale that this delay is necessitated by "other priorities" required for MISO to achieve its mission of electric system reliability is both illogical and irrational.  The simple truth of the matter is that MISO will need to accelerate its timetables for implementation of BOTH Order 2222 AND its other LTEP priorities to have any realistic chance of assuring electric system reliability in the face of the foreseeable challenges of the Climate Crisis in both the near and the longer term.  MISO should have the foresight, the insight, and the courage to recognize this reality and to seek, acquire and deploy the additional resources required (as they surely will be) to meet these accelerated timetables.

For the same compelling reason, neither MISO nor its Stakeholders have the luxury of wasting any of the time during the SEP which would result from the role and resources constraints which MISO staff disclosed during the August 11 DERTF meeting had been imposed by its governing body(ies) on its participation in DERTF Management Plan Development.  Accordingly, MISO's governing body(ies) should reconsider these unwise and unwarranted constraints on the MISO staff's participation in Plan Development during the SEP.

In the meantime, SI expresses its readiness and willingness to work with other Stakeholders to coordinate their roles and resources in order to make the best use possible of the SEP in Management Plan development.

Thank you.

Michael A. Mullett

Board Member and Advocacy Team Lead

Solarize Indiana, Inc.

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resources Task Force (“DERTF”) on the feedback request made by MISO at the August 11, 2022, meeting of the DERTF.[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 August 11^th meeting of the DERTF, MISO requested feedback on topics for consideration in the development of the management plan for the DERTF. AEMA offers the following feedback:

• The DERTF should have updates on Order 2222 developments as a standing agenda item. This can include developments at MISO and within the RERRAs. Although MISO has chosen an extended implementation date, many states within MISO will be moving much quicker to implement DER Aggregation into other markets like PJM and SPP, which have tighter implementation dates. The DERTF is a logical discussion group to monitor these developments for lessons learned. For example, how are RERRAs moving forward with coordination and rule development between the DERA-EDC-LSE-TO-ISO/RTO-RERRA? 
  
  
• The next DERTF should include a detailed review of the “Outstanding Tasks of the DER TF” from the Task Force Extension Notice.[3] This discussion would clarify the scope of the topics listed and potentially populate the management plan for subsequent meetings. The comments by the Environmental Sector suggested something similar by noting that many of these topics “require clarification.”[4]
  
  
• Per the recommendation from the Environmental Sector, a series of informational sessions and updates on the state level plans/progress/challenges/processes to prepare for implementation of Order 2222 would be useful.
  
  
• Discussion of how non-market DERs could be accessed and utilized in the current and short-term future of MISO operations. What level of detail is needed by MISO for transmission modeling of non-market DER?
  
  
• Review state level development of pilot program initiatives and how those might be integrated into MISO planning, reliability, and operations processes.
  
  
• Baseline accreditation methodologies. This topic has been raised by the IMM and other commenters on Order 2222. The DERTF could serve as a venue for detailed discussion of these issues and related topics.
  
  
• At the most recent Steering Committee, MISO staff surfaced a potential process to purge parking lot issues at periodic intervals. How will MISO handle the “parking lot” issues for Order 2222, particularly since the implementation of compliance appears to be 8 years away. 

AEMA appreciates MISO’s consideration of these comments as part of the examination of DER opportunities within MISO. 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

The OMS DER Work Group appreciates the opportunity to submit feedback regarding potential topics to be added to the DERTF management plan. The OMS DER Work Group generally agrees with the priorities in the list compiled by the Environmental Sector and would like to highlight a few priorities for the DERTF’s consideration.  

1. Meeting Cadence - The OMS DER Work Group strongly supports the restart of the DERTF and would encourage flexibility in meeting scheduling to adapt to stakeholder needs and FERC actions. While quarterly meetings are an appropriate place to start, MISO should not hesitate to move placeholder meetings or schedule additional meetings as stakeholders request and as there is content to discuss. As an example, it would be appropriate for MISO to move the November 2022 meeting up to September or October 2022 to discuss MISO’s response to FERC’s August 12th information request to MISO as well as to set the management plan. The OMS DER Work Group appreciates that a DERTF was recently scheduled for October 21, 2022.

2. RERRA raised coordination and issues - The OMS DERWG agrees that this is a very important priority and recognizes that OMS and individual commissions will need to bring forward issues for DERTF consideration and discussion in the future. While not all OMS members have created Order 2222 specific dockets and/or may not currently have specific issues to discuss in the near term, the OMS DER Work Group expects to stay apprised of RERRA developments and will not hesitate to bring challenges that RERRAs are encountering to the DERTF as needed.  

3. Automated registration review, including building and testing - The OMS DER Work Group sees this item as something MISO and its stakeholders could work on even before FERC’s action on compliance. An automated process to handle incoming registrations is almost certainly going to be needed regardless of changes to MISO’s compliance and also has the potential to improve current market products, such as Demand Response. The current practice of manually sharing Excel spreadsheets among the RTO, RERRA, DR aggregator, LSE, and EDC is not ideal and will become increasingly impractical as DER penetration expands and more aggregators are active in this space.  

4. Metering data repository establishment coordination with data access requirements - Similar to #3 above, the current manual process for exchanging data is not ideal and subject to potential errors. For instance, a private customer's information could potentially be released through a simple mistake such as sending information to the wrong email address. The data repository concept was raised in past DERTF meetings as a way to track dual participation in retail programs and MISO markets and to prevent double counting (see MISO Superdeck and August 2021 stakeholder feedback). While this concept was ultimately not included in MISO’s compliance filing, it would be an improvement over the status quo and could represent an ideal future state. The OMS DER Work Group recognizes that more work needs to be done to fully flesh out this concept, particularly on how to ensure only the appropriate parties are able to access the necessary data in a secure manner. However, the data repository is worth pursuing and is again an item that MISO and its stakeholders could work on while Order 2222 compliance is underway.  

This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.

Xcel Energy appreciates the opportunity to provide our recommendations for the DERTF management plan. We believe that the priority tasks focus on building the systems needed for registration and data coordination, metering and telemetry rules and affected system study coordination.    All of these tasks will require extensive coordination between MISO, RERRAs, DERAs and EDCs to develop standards for efficient processes. 

The priority tasks from the DERTF Memo to the MSC that we recommend starting during the following year of the DERTF include: 

• Automated registration review - building and testing
• Affected Systems Study Coordination
• Communication hub for DERAs, RERRAs, MISO on issues that are unknown, but expected
• Metering and telemetry rules – coordination at state level and relevant MISO requirements
• Metering data repository establishment and coordination with relevant data access
• requirements
• MISO Tools for DEAR registration – enrollment and modifications
• RTO-level Registration review process

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: MANAGEMENT PLAN TOPICS
DATE: AUGUST 30, 2022

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to MISO’s request during the August 11, 2022, Distributed Energy Resource Task Force (DERTF) meeting concerning DERTF Management Plan Topics. 

In general, the EOCs are in support of the topics identified in the Environmental Sector’s presentation delivered at the August 11, 2022, DERTF meeting.  This list covers the bulk of items that the EOCs had identified in the Sunset Provision feedback, previously submitted to MISO on January 24, 2022.  However, we believe that the Measurement and Verification enhancements, including the use of before/after metering instead of baselines, should be a high priority.   

 The EOCs appreciate the opportunity to comment.