DERTF: Order 2222 Tariff Language (IR070) (20220113)

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – ORDER 2222 TARIFF LANGUAGE
DATE: JANUARY 27, 2022

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the January 13, 2022, Distributed Energy Resource Task Force (DERTF) meeting concerning the FERC Order 2222 filing framework and the related Order 2222 Tariff language edits to Modules A, D and E-1; Attachment MM; Schedules 16-A, 27 and 53. 

Module E-1 & Schedule 53 Tariff Edits:

• The EOC’s agree with Module E-1 69A.4.1.i, which states that the Distributed Energy Aggregated Resource (DEAR) seasonal accredited capacity will be based on the sum of the individual accredited values of the underlying Distributed Energy Resources (DERs) within the aggregation as set forth in subsections a-h.
• In Schedule 53, paragraph one states that the Seasonal Accredited Capacity (SAC) does not apply to a DEAR.  Assuming the resource(s) will be registered as a DEAR resource type and not that of the underlying DERs, should Schedule 53 add clarifying language that the Seasonal Accredited Capacity (SAC) would still apply to the underlying DERs in the aggregation?     

Modules A, D; Attachment MM; Schedules 16-A and 27:

• We have no edits at this time 

The EOCs appreciate the opportunity to comment.

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the feedback request made by MISO at the January 13, 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 January 13^th meeting of the DERTF, MISO proposed tariff language changes to Modules A, D, and E-1; Attachment MM; and Schedules 26-A, 27, and 53. In response to the proposed tariff language changes, AEMA offers the following feedback:

• Module A: Definitions:

Proposal Summary: MISO proposes to update the definitions of Actual Energy, Bi-Directional Ramp Rate Curve, Blackstart Unit, Capacity Resource, Commitment Status updated to include Distributed Energy Aggregated Resource, Deficient Energy, and Dispatch Status updated to include Distributed Energy Aggregated Resource.

MISO has added new definitions for Distributed Demand Response Resource, Distributed Energy Aggregated Resource (DEAR), Distributed Energy Aggregated, 

Distributed Energy Resource (DER), Distributed Energy Resource Aggregator (DERA), Distributed Energy Resource Group, Distributed Generation Resource, and Distributed Storage Resource. MISO has updated the definitions of Energy Resource, Excessive Energy, Hourly Bi-Directional Ramp Rate, Hourly Economic Maximum Limit, Hourly Economic Minimum Limit, Hourly Emergency Maximum Limit, Hourly Emergency Minimum Limit, Hourly Ramp Rate, Hourly Regulation Maximum Limit, Hourly Regulation Minimum Limit, Hourly Single-Directional-Down Ramp Rate, Hourly Single-Directional-Up Ramp Rate, Incremental Energy Cost, Measurement and Verification, Offer, On Line Supplemental Reserve Offer, Regulating Reserve, Regulation Qualified Resource, Resource, Short-Term Reserve Qualified Resource, Spin Qualified Resource, Supplemental Qualified Resource, Up and Down Ramp Capability Qualified Resource, and Use Limited Resource updated to include Distributed Energy Aggregated Resource.

AEMA Feedback: AEMA has no opposition to the suggested changes.

• Module D: Market Monitoring and Mitigation Measures:

Proposal Summary: MISO has proposed to add Electric Distribution Companies to the entities that will be monitored for favoritism and anti-competitive behavior. MISO has also added Distributed Energy Aggregated Resources (DEARs) to the list of resources that will be monitored and audited by the IMM for Physical Withholding including granting access to operational information and data from the Transmission Provider. In addition, proposed changes grant the IMM access to operational data and information on DEARs and adds DEARs to the resources for which mitigation measures and competitive conduct review may be applied. MISO proposes a 10 MW demonstrated injection capability threshold to the physical and economic withholding and uneconomic production review. Demand Response is already fully excluded from these reviews. MISO adds Distributed Energy Aggregated Resources to the list of Planning Resources for which facility-specific reference levels can be established.

AEMA Feedback: AEMA supports the proposed tariff revisions including the monitoring of Electric Distribution Companies by the IMM and establishment of a 10 MW demonstrated injection capability threshold for application of Market Monitoring and Mitigation. AEMA also supports the exclusion from Market Monitoring and Mitigation for Demand Response Resources of all sizes. MISO should expand the exclusion of resources with less than 10 MWs of injection capability to the Module D sections on retention of operating/cost data by the DERA. Many DEARs may be composed of dozens or hundreds of individual resources. Maintaining individual cost profiles for small resource aggregations that are not subject mitigation does not add value and could be a barrier to participation for DERA seeking to participate in the MISO market. 

• Module E-1: Resource Adequacy

Proposal Summary: MISO proposes to add Distributed Energy Aggregated Resource (DEAR) to the list of resources eligible to become a Capacity Resource with the same qualifications of existing resources. MISO adds language on the Determination of Deliverability for a DEAR wherein MISO proposes that the Transmission Provider will be responsible for determining whether DEARs are eligible to be Capacity Resources deliverable to Load. The DERA will coordinate with the EDC to perform a technical review of the DEAR. Any "injecting MW" would be required to "demonstrate deliverability by obtaining External Network Resource Interconnection Service or procuring firm Transmission Service." MISO proposes to use a summation of the individual accredited values of the underlying Distributed Energy Resources within an aggregation, based upon resource types for Seasonal Accredited Capacity (SAC) credit. 

AEMA Feedback: AEMA supports the proposal to only require deliverability on injecting MWs and utilization of the summation of resource types for SAC determination. AEMA remains concerned about the process that the EDC will utilize to perform their technical review of the DEAR. At a minimum, MISO should establish a process to allow the DERA to request deliverability review directly from MISO if there is a concern about the objectivity of the EDC review. Additionally, since the tariff language for the Seasonal Accreditation Capacity Calculation is pending approval at FERC, AEMA requests that MISO establish additional feedback requests concerning the draft tariff language related to DEAR capacity accreditation if substantive revisions to the MISO Tariff are proposed in the future. 

• Attachment MM: Multi-Value Project Charge (MVP). 

Proposal Summary: MISO proposes to exclude Net Actual Energy Withdrawals associated with Distributed Energy Aggregated Resources from MVP charges.

AEMA Feedback: AEMA supports this exclusion. 

• Schedule 26-A: Multi-Value Project Usage Rate

Proposal Summary: MISO proposes to exclude Net Actual Energy Withdrawals associated with Distributed Energy Aggregated Resources from MVP charges.

AEMA Feedback: AEMA supports this exclusion.  

• Schedule 27: RTORSGP and DAMAP

Proposal Summary: MISO proposes to add Distributed Energy Aggregated Resources to the resources eligible for RTORSGP (Real-Time Offer Revenue Sufficiency Guarantee Payment) and DAMAP (Day Ahead Margin Assurance Payment).

AEMA Feedback: AEMA supports this inclusion.

• Schedule 53: Seasonal Accreditation Capacity Calculation

Proposal Summary: MISO proposes to add Distributed Energy Aggregated Resource (DEAR) to the excluded resources that will use Schedule 53 for determining SAC. The SAC for DEAR is determined elsewhere. 

AEMA Feedback: AEMA supports this modification.  

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

ITC Order 2222 Tariff Language (Modules A, D & E-1, Attachment MM, and Schedules 26-A, 27 & 53) Comment

Comments for Module A--Definitions

• Injection and withdrawals at the BES level should be metered, reported and settled separately on a 5-minute basis. Netting should occur in terms of dollars at the settlement statement level, not in terms of offsetting energy because the value of the energy is not the same in each interval of the hour. Aggregating/netting at the hourly level does not accurately value the energy on a 5-minute basis.  MISO implemented 5-minute settlement in 2018.  And MISO itself notes the importance of measurement and settlement at the 5-minute level.  Please see:  https://www.misoenergy.org/about/media-center/miso-partners-with-customers-stakeholders-to-complete-transition-to-five-minute-settlements/
• If MISO chooses to allow netting and/or calculation instead of actual measurement, we respectfully suggest that MISO specifically identify these situations and explain why calculations are more just and reasonable than measurement. 
• Consider adding a discussion of periodicity to the definition of LMP.

Comments for Module D – IMM Module on Physical Withholding:    None

Comments for Module E-1 – Resource Adequacy:  None

Comments for Attachment MM--MVP Charge, Schedule 26-A – MultiValue Usage Rate

• ITC opposes exempting the broad class of DEARs from the MUR.  The purpose of the MVP portfolio is to provide transmission to support MISO States’ renewable energy mandates.  Thus, quite simply, the MVP’s support DEARs.   
• The MVP Portfolio facilities centralized dispatch of generation resources which brings operating efficiency to the region and spreading the benefits of low-cost generation throughout the MISO footprint. Further, the MVP Portfolio provides benefits across the MISO footprint in a manner that is roughly equivalent to costs allocated to each LRZ.
• DEARs will benefit from the MVP transmission and there is no justification to exempt these resources for their usage of the overall MISO transmission system.  In fact, not charging them will create a cross-subsidization where other resources will pay for the incremental portion of the MUR for which DEARs are responsible. 

Comments for Schedule 27 – Real-Time Offer Revenue Sufficiency Guarantee:  None

Comments for Schedule 53 – Seasonal Accredited Capacity:  None

 Thank you,

Marguerite Wagner, ITC

WPPI included its feedback (track changes and comments) on the proposed tariff language changes for MISO O2x4 compliance in the “redlines” documents posted with the DERTF, 1/13/2022 meeting materials:

• Item 07a Module A – Iteration 2 Redlines
• Item 07b Module D – Iteration 2 Redlines
• Item 07c Module E – Iteration 1 Redlines
• Item 07e Schedule 27 – Iteration 1 Redlines
• Item 07e Schedule 53 – iteration 1 Redlines

In addition, in the cases of Attachment MM (Item 07d Attachment MM – Iteration 1 Redlines) and Schedule 26A (Item 07e Schedule 26A – Iteration 1 Redlines): MISO needs to explain why a DEAR (aggregation of DERs) should be exempt from the MVP Usage Rate.

The redlines for Module D, Section 54.1 "Access to Transmission Provider's Data and Information" item (g) require the TP to provide the IMM with data and information related to the redispatch of a DEAR by an EDC to manage distribution system congestion. We oppose the addition of this language. Neither the IMM nor MISO have authority over the EDC's operation of the distribution system or the EDC's data and information related to operation of the distribution system, including distribution congestion. We disagree that the TP should be required to obtain such data and information from the EDC and provide it to the IMM.