DERTF: Order 2222 Tariff Language (MSC-2019-2) (20220317)

Item Expired

Related Entity(s):

Distributed Energy Resources Task Force (DERTF)

Topic(s):

Energy Markets, Energy Storage, Distributed Energy Resources (DER)

During the March 17, 2022, Distributed Energy Resources Task Force (DERTF) meeting, MISO reviewed proposed tariff language changes to Modules A, B, C, D, E-1, Attachments MM, TT, UU and Schedules 26A, 27, 29, 29A and 53. Stakeholder feedback is requested on the proposed language.

Please provide feedback by March 21.

Submitted Feedback

ITC Holdings Submitted by Marguerite Wagner

Posted - 03/22/2022

ITC Comments from 3/17/21 DERTF draft Tariff documents

Module A

ITC appreciates the continued refinement of the definitions.

Comments/Questions:

For the definition of Dispatch Target, it may not always be the case that a DEAR requires a reduction in consumption to inject—so including it inside the parenthesis may not be appropriate.

Module B

ITC does not have specific comments on the language changes in Schedule B at this time.

Module C

ITC supports the changes to coordination that include TOs. We also support the clarification provided regarding offers from DEARs.

Question

As proposed, MISO appears to contemplate that a DEAR might cross EDC boundaries. Early on we understood that this was not permitted. Has this changed? Language below:

“The EDC(s) where the DER(s) comprising the DEAR are located, with relevant contact information as set forth in the Business Practices Manuals.”

General Comment: We appreciate the changes MISO has proposed in Module C to include TOs. At this point it is not possible to tell if all interaction points have been identified but we trust that MISO will work with parties to resolve any potential issues as the Business Practice Manuals are developed.

Module D

MISO appears to have made several changes in Module D that do not appear to have not been discussed and seem to merit discussion in the DERTF.

Module E-1

MISO proposes these, among other changes:

C. Determination of Deliverability of Distributed Energy Aggregated Resources

The Transmission Provider shall be responsible for determining whether Distributed Energy Aggregated Resources eligible to be Capacity Resources are deliverable to Load. The Distributed Energy Resource Aggregator will coordinate with the Electric Distribution Company in order for the Electric Distribution Company to perform a technical review of the Distributed Energy Aggregated Resource’s transmission system impacts. Any MW found to be injecting onto the transmission system as a result of the technical review must demonstrate deliverability by obtaining External Network Resource Interconnection Service or firm Transmission Service in order to qualify for the Planning Resource Auction or a FRAP.

We suggest that TOs may need to be included in the language above and at all locations where study of the Transmission System is involved.

Attachment MM

We continue to oppose exempting DEARs from the MVP Usage Rate. We have filed other comments on this point previously.

Attachment TT

We reiterate our concerns that resources at the distribution level should be measured and metered directly at each applicable location. This is imperative to ensure accurate performance and settlement. Moreover, resource capability on the distribution system will impact the commitment and availability of resources on the bulk electric system. Thus, understanding the specific capabilities and performance of resources on the distribution system becomes ever more important to situational awareness and system operation.

Attachment UU

We did not see any proposed changes in this section.

Schedule 26-A

We continue to oppose exempting DEARs from the MVP Usage Rate. We have filed other comments on this point.

Schedules 27, 29, 29A

ITC does not have specific comments on the language changes in these Schedules at this time.

Schedule 53

Will MISO be considering an availability criterion or some other metric to more closely align treatment of DEARs with other resources in Schedule 53?

Entergy Services Inc. Submitted by Robert Francis

Posted - 03/22/2022

MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – ORDER 2222 TARIFF LANGUAGE
DATE: MARCH 21, 2022

The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the March 17, 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, B, C, D and E-1; Attachment MM, TT and UU; Schedules 26A, 27, 29, 29A and 53.

Module C – Energy and Operating Reserves Market

As suggested in the Tariff redlines that were submitted to MISO on February 24, 2022, the following verbiage should be added to the Metering requirements in Tariff section 38.2.5.e.v.(a.), “Resources that are part of a Distributed Energy Resource Aggregation (DEAR) should use the retail meters of the relevant Electric Distribution Company (EDC) for settlement unless the EDC has agreed to the use of third-party metering for settlement.” Assuming MISO does not accept this recommendation, the following provisions should be added:

In Section 38.7 D. Settlements – add the following phrase: “The DEAR settlement information can be viewed by the LSE, EDC, and LBA via the Market Portal once the Hourly Ex Post LMPs are approved. The DEAR settlement information accessible to the LSE, EDC, and LBA via the Market Portal includes but is not limited to the: meter data, calculated baseline, MW reduction, injection or withdrawal for the DERs and DER Groups in a DEAR, as applicable and hourly Dispatch Target for Energy.”
In Section 38.7 E. Audit Rights - the following sentence should be added to the section: “The Transmission Provider reserves the right to audit or verify the information provided by a Market Participant or DERA including, but not limited to, information related to the registration, claimed capacity, operations, modeling, metering, settlements and/or any other information related to the participation of the DERA, DEAR or individual DER under this Tariff. If there are discrepancies of 10% or more in the meter data between any third-party metering systems used in the DEAR and EDC metering, at the request of the EDC, the Transmission Provider will audit the meter data for the DERs in a DEAR.

Under Market Participation Application and Qualification, Section 38.2.2.h, which in part reads “A Market Participant Applicant seeking to submit Distributed Energy Aggregated Resource Offers in the Energy and Operating Reserve Markets shall: (i) demonstrate to the Transmission Provider that it has exclusive rights through ownership, operational control, or other contractual rights to the output of such Resources, (ii) that such Resources are capable of responding to the Dispatch Target and, if applicable, Setpoint Instructions;…”, could MISO provide clarity as to whether or not this means that that all Distributed Energy Aggregated Resources must follow a 5-minute dispatch target? If not, will this language be updated to reflect that?

In the Distributed Energy Aggregated Resource Offer Rules in the Day-Ahead Energy and Operating Reserve Market Section 39.2.5E.b xi, xii, xv, xvii, xix and the related Distributed Energy Aggregated Resource Offer Rules in the Real-Time Energy and Operating Reserve Market Section 40.2.7C.b xi, xii, xv, xvii, xix - it was noted that for iteration 2 of the Module C Tariff redlines that there were several instances where the use of minimum, maximum, greater than and less than were switched with their opposite for offer parameters related to both continuous and withdraw modes of operation. Use cases that have been presented as a part of the DERTF indicated that withdraw offers would be done so using negative numbers (MWs). If so, the current version of these specific offer parameters might not be correct. It would be helpful if MISO could provide examples related to these offer parameters and how moving up and down the number line impacts this verbiage.

Schedule 53 Tariff Edits

As stated in previous feedback, there appears to be a conflict between Module E-1 69A.4.1.i and paragraph 1 of Schedule 53 which we detail below.

The EOCs agree with Module E-1 69A.4.1.i, which states that “The Seasonal Accredited Capacity for a Capacity Resource that is a Distributed Energy Aggregated Resource will be determined by the Transmission Provider based on the sum of the Seasonal Accredited Capacity values of the underlying Distributed Energy Resources within the aggregation. The Seasonal Accredited Capacity values of the underlying DERs will be determined based on their corresponding resource types as set forth in subsections above and in accordance with the BPM for Resource Adequacy 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.”

However, in Schedule 53 paragraph 1, MISO 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?

Attachment TT

The EOC’s ask that the following language be added to Attachment TT:
- All existing behind-the-meter generation that opts into FERC Order 2222 must be separately metered in accordance with the EDC’s Interconnection Standards in which a separate utility meter shall be installed on the DER output at the point of common coupling.
- Demand response associated with load reduction will be measured & verified via utility smart metering with load measurements verification of the network taken before and after the initiation of the demand response signal.

Modules A, B, D and E-1; Attachments MM and UU; Schedules 26A, 27, 29 and 29A

We have no edits at this time

The EOCs appreciate the opportunity to comment.

[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.

Advanced Energy Management Alliance Submitted by Katherine Hamilton

Posted - 03/21/2022

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 March 17, 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.

Prior to providing formal Tariff language feedback, AEMA finds it appropriate to express our general dismay and extreme concern regarding the proposed Order 2222 implementation date of 2030, presented at the March 10, 2022, Market Sub-Committee Meeting.[3] The proposed 2030 implementation timeline is exceptionally disappointing to AEMA members; specifically given other ISOs/RTOs plan to implement Order 2222 six years prior to MISO. For example, at the Tuesday, March 16^th, SPP Markets Working Group meeting, SPP indicated it is on schedule to submit its Order 2222 compliance filing on April 28, 2022- and may file sooner. But most notably, SPP considers 2024 to potentially be a reasonable implementation timeframe.

AEMA requests MISO re-examine the implementation timeline and identify opportunities in which DEARs can more efficiently be pulled into the MISO markets. At a minimum, MISO should not pause the implementation of Order 2222 from the time the Market System Enhancement (MSE) is completed (2025) until after the MCR is completed (2028). Preferably, MISO should examine the opportunity to allow DEAR to participate in the markets, even on a limited basis in the immediate time horizon. For example, could a DERA participate under existing models initially, while the MSE is completed to allow broader participation? What could be done to establish immediate opportunities for DERs? These are the questions MISO should examine to be proactive in the integration of DERs into their marketplace, as opposed to waiting to react to the growing influx of resources. AEMA recommends that MISO also initiate a study to quantify the market benefits that may be realized through enabling DEAR participation to be compared to the potential MCR benefits.

We understand MISO has been working on DER integration in the market in various forms following the FERC Notice of Proposed Rulemaking (NOPR), issued in November 2016; leading to the issuing of Order 2222. However, the proliferation of DERs in the United States will continue. The landscape of DERs and customer solutions is rapidly evolving. MISO delaying market participation another eight to ten years removes market efficiencies and expanded opportunities to reduce consumer operating costs. MISO can ill afford to ignore the impact such resources have on Market Operations during this time.

Further, at the March 17^th meeting of the DERTF, MISO posted the latest redline Tariff changes to Modules A, B, C, D, and E-1. The latest versions of Attachment MM, TT, and UU were also posted at that time. In response to the proposed tariff language changes, AEMA offers the following feedback:

Module A: Definitions

Proposal Summary: MISO proposes to add clarifications on Actual Energy Injections and Actual Energy Withdrawal; remove Energy Efficiency in a DEAR from Capacity Resource definition; add DEAR to options for Blackstart Equipment; add clarifications on the determination of Operable Capacity for DEARs; include new definitions related to market participation parameters; and add clarifications to Dispute procedures.

AEMA Feedback: MISO should clarify in the definition of Energy Efficiency (EE) Resource that in addition to resources installed on “retail customer facilities”, any DER that can achieve permanent reduction in electric energy usage should qualify as an EE Resource, no matter where it is connected.

In Section 12, 33.0.0, e., AEMA suggests that the proposed language contains a typographical error as follows: “Disputes relating to the interconnection of a DER with an EDC, expect except disputes regarding the potential impact of such interconnection, of the impact of a DEAR, on the Transmission System.”

AEMA has no additional feedback about the remaining changes.

Module B: Transmission Service:

Proposal Summary: MISO has proposed no additional changes to the previous iteration.