During the January 13, 2022 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed its proposal to proceed with the Task Force sunset date as written in the Charter approved by the Steering Committee in May 2021. Stakeholders are invited to provide comments with focus on the following questions:
Please provide feedback by January 24.
WEC Energy Group supports a one-year extension of the sunset date for the DERTF. In our assessment, it took some time for the DERTF to gain momentum and participation from EDC SMEs that typically do not participate in MISO stakeholder forums. The DERTF needs to take advantage of that momentum and continue its regularly scheduled meetings. As noted in the Jan 18 DER workshops, there are several issues that are outside of MISO's purview but require coordination with MISO and the TOs. As the RERRAs and EDCs expand their integration of DEARs, we anticipate the need to address coordination and implementation issues - the DERTF is the best group to deal with those issues. If the DERTF sunsets, we will loose the momentum gained from the participation of EDC SMEs. EDC SMEs do not have the bandwidth (nor desire) to participate in the regular main parent entity (MPE) meetings because those meetings are not focused strictly on DER issues. Additionally, the MPEs are scheduled to meet only 8 times in 2022 rather than the typical monthly meetings. This will put additional pressure on the meeting agendas in terms of the amount of material covered, which will discourage active participation from the EDC SMEs. Reducing the MPE meetings from 12 per year to 8 will also result in less time to deal with each agenda item, perhaps to the point of rendering the agenda item moot, especially if the requisite SMEs are not participating. Maintaining the DERTF for at least another year will mitigate these concerns.
WEC Energy Group reminds MISO that the stakeholder process, while supported by MISO, is owned by the stakeholders. MISO's opinion is important when making entity sunset decisions, but the decision is not MISO's to make. Only stakeholders can make that decision.
The Organization of MISO States Distributed Energy Resources Workgroup (OMS DER WG) is appreciative of MISO accepting comments on this issue. The OMS DER WG first wanted to express its support for following the governance guide and established procedures for review and discussion surrounding the future of the MISO DER Task Force (DER TF).
1. Should the DER conversation continue at a stand-alone entity at MISO?
The OMS DER WG supports the continuation of a stakeholder entity in some form. The OMS DER WG is open to ideas to creatively solve this unique multi-faceted, multi-stakeholder, and multi-committee set of issues.
Due to the on-going and evolving nature of these topics related to DER-integration, and the overlapping jurisdictional, and multi-stakeholder coordination needs, MISO should continue to provide a one-stop shop for information, communication, and understanding of these issues. At a minimum MISO should provide clear guidance or a process map for where DER-related issues can be brought and where they can be discussed in a timely manner once identified. If the DERTF is sunset MISO should retain existing tools to foster this request – including the DER TF stakeholder email list. Using the Integrated Roadmap (or future IR-like replacement) as the ‘home’, even if on a rolling and more frequently revisited basis, will not be sufficient. It is known today, and has been repeatedly acknowledged in the DER TF discussions, that changes or further work on the DER-aggregation market product is will be needed. The issues we will face will need more timely action and attention than sunsetting of the DERTF will afford.
The OMS DER WG finds this comment period to be a useful first step for stakeholders to better understand each other's position on this issue, so that if needed - as the original proposers of the DER Charter and DER TF envisioned - the OMS, and other stakeholders, can have discussions and propose solutions to issues as they arise at MISO (or elsewhere). Continuation of a group in some manner is consistent with other RTOs; e.g. PJM’s compliance filing is due 2/1/2022 and their Subcommittee will continue to meet as early as 2/25/2022 to discuss their parking lot items. PJM currently has meetings scheduled through June 2022.
This has been a longstanding issue, one of joint importance to MISO and OMS. OMS has established DER’s as a strategic priority again in 2022 and continues to support the OMS-MISO Joint Priorities Statement.
The OMS DER WG is interested in hearing from other sectors on this issue to better understand whether the OMS DER WG’s needs are similar to other sectors.
2. For what explicit reasons should a stakeholder entity continue?
Including the reasons discussed above, the OMS DER WG believes that some heightened plan for continued DER-topics is needed to ensure coordination, communication, and visibility into cross-jurisdictional, multi-sector DER-issues. The OMS DER WG acknowledges that DER-issues are unique in that they involve participants that are not routinely following other MISO subcommittees. Therefore, stakeholders will need additional help identifying where DER-related work it taking place at MISO so that they can maintain a holistic view of MISO’s progress. It will be particularly difficult to ensure robust participation from all relevant stakeholders as many relevant stakeholders are not routine MISO-stakeholder process participants.
MISO at a Logical Intersection for this work: As MISO is at the intersection of these issues, it makes sense that this forum should be at MISO. A forum at MISO is the only means to integrate these conversations into wholesale products, planning, and coordination frameworks, and a cross-sector stakeholder group is already established, at least for some of the conversations that need to be further developed. The OMS DER WG acknowledges this despite the fact that MISO and stakeholders will need to share the responsibility of driving future work in this area.
Effective Integration of DERs: Ensuring DERs are effectively integrated into MISO processes and products and considered at the wholesale level is important to retail regulators as they strive to ensure these resources’ use and value is maximized at the retail level. Both MISO and retail regulators will have to work together to ensure these system resources are properly accounted for. The MISO stakeholder forum is needed to ensure that occurs.
The OMS DER WG continues to believe that in ensuring the success of the DER-aggregation product, it is important that distribution and wholesale system options and resources are both optimized where they interoperate and are fully utilized. This evaluation of the DER-A market product and DER-issues will be an iterative need, not one that stops at MISO submittal of a FERC-Order 2222 Compliance Filing. There are ongoing issues related to DERs and their effects on energy and resource adequacy, reliability, and interconnection that need further discussion and heightened visibility and involvement from stakeholders.
Visibility and Tracking of DER Issues: Having a known one-stop shop at MISO to track and monitor on-going DER issues would be optimal. Issues could arise both within the stakeholder entity, as well as via updates from other subcommittees that may be tackling other DER-adjacent issues. A one-stop shop helps ensure all stakeholders, especially newer entrants having an interest in DER-related issues can be engaged and educated more effectively. States have found it invaluable to have established groups, email lists, and a ready-set list of key personnel to tackle DER-issues as they arise.
Transparency: A MISO stakeholder group would ensure DER discussions continue in a public forum. This is an invaluable benefit MISO provides. While the states will certainly need to evaluate processes, tariffs, rules, etc. outside of this stakeholder group, a standing forum within this existing public forum to discuss a host of on-going, future, and yet to be known, DER issues would greatly inform state level activities and ensure effective alignment to RTO processes.
Prior to the DER TF, considerable coordination efforts and discussion occurred on these issues (work that began in 2017 and resulted in OMS and MISO’s Joint Priorities), and the OMS DER WG found those conversations robust and useful. The OMS DER WG finds these long-standing issues outlined and discussed between MISO and OMS as key areas that will grow in importance if they are to be implemented well. These issues need to continue to involve an appropriate set of stakeholders in the MISO footprint. The issues flagged and discussed between OMS and MISO will not go away with the filing of the Order 2222 Compliance Filing.
Keeping DER Prioritized: DER-issues will only grow in importance and impact, both as a resource to be utilized for system reliability and flexibility, as well as incur issues and unforeseen implications to existing market products, MISO processes, and system needs.
Dispersing the task force may have the unintended consequence of diminishing the importance of DERs to both the state and wholesale system, having the opposite effect of what FERC intended with Order 2222.
Point of Coordination for Order 2222: In addition, a forum dedicated to DER issues could serve as a component of the coordination requirements included in Order 2222. Aside from the written coordination details that the OMS DER WG assumed will be included in MISO’s initial compliance filing, a MISO stakeholder group could function as a place to have ongoing discussions among all the parties that will be involved in coordinating DER aggregation, including RERRAs, EDC, DERAs, and MISO. Over the past year, MISO has consistently framed its initial compliance filing as a first step, with details needing to be worked out in BPMs and through engagement with RERRAs in the years to come. As RERRAs develop new rules and regulations surrounding DER aggregation, a standing stakeholder group to address new and existing issues and problems will be essential to the success of MISO’s Order 2222 compliance and is contemplated by FERC (§ 35.28(g)(12)(ii)(g)).
The OMS DERWG looks forward to the written details of MISO’s coordination framework and suggests that the continuation of a DER stakeholder entity as a piece of this framework could be included in MISO’s compliance plan which would bolster the quality of MISO’s compliance and better meet the needs of its stakeholders than simply sunsetting the DERTF.
3. What topics should be covered, what's left from O2222, what's on-going from O2222, what other issues should be addressed?
OMS foresees that further discussion on the following topics will be needed, particularly as states and EDCs develop rules and processes beyond the scope of MISO’s compliance and as pertain to increased penetration of DERs in the future:
DER Issues Generally
4. If sought, what format the group should take (TF, WG, or is the proposal from MISO - in that topics are dispersed to other subcommittees or task teams appropriate?
The OMS DER WG strongly prefers that the standalone DER task force or work group be maintained, rather than attempting to address DER issues through the various subcommittees.
This approach is appropriate for the DER specific work and problems that the DER group would be asked to solve. By nature, DERs are hosted on the distribution system and, therefore, distribution experts will need to be involved in these discussions. It would be inefficient to ask these experts to sit through and keep track of lengthy subcommittee meetings where DER issues would only account for a portion of the agenda. For example, DERs issues can be expected to develop in resource and energy adequacy, and interconnection, among other areas, all of which would currently be assigned to a different MISO entity and could cause DER issues to take a back seat to other issues discussed at the subcommittee level.
The OMS DERWG recognizes that discussions at the standing MISO subcommittees will certainly have an impact on DER aggregation but suggests that it would be more efficient and effective for these discussions to be summarized for the DERTF in an informational update, instead of spinning off DER issues to various subcommittees. This will allow stakeholders to holistically digest and discuss DER-related issues.
Largely, the organizations that are most-closely tied to DERs and DER-A issues are not tracking all of MISO’s subcommittees and would be nearly impossible to monitor all of those subcommittees to remain up to speed on DER-related decisions. At a minimum MISO shoujld rep
5. What timing aspects should be considered?
While an early FERC Order on compliance would be ideal there are topics that could be continued and discussed in the interim, while FERC evaluates MISO’s filing. The DER TF should be flexible to accommodate meetings as necessary long-term, but likely to be on a less-than monthly basis (potentially quarterly, and as needed). As many stakeholders have noted, it is much easier to cancel a meeting than to schedule one. The frequency of meetings may again increase during the lead up to MISO’s launch of Order 2222 market offerings in order to address any changes that will inevitably occur over the coming years, as well as providing updates on Market System Enhancement activities that affect DER/DEAR stakeholders.
If the DERTF is not sunset, the OMS DER respects that many of the issues that need further discussion and work cannot be MISO-led, and instead, stakeholder-to-stakeholder coordination is needed to make progress. If a stakeholder forum is continued, the OMS DER WG stresses that these meetings will need increased stakeholder presentations and involvement to progress.
MEMORANDUM
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: DISTRIBUTED ENERGY RESOURCE TASK FORCE SUNSET DATE
DATE: JANUARY 24, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to MISO’s request during the January 13, 2022, Distributed Energy Resource Task Force (DERTF) meeting concerning the DERTF sunset date of July 31, 2022, in particular:
Regarding further discussion on this topic, Entergy requests that MISO clarify whether there is an intent for the DERTF to meet after the filing is made, but before the sunset date established in the Charter.
1. The DER conversation should continue at a stand-alone entity at MISO
2. Reasons for a stakeholder entity to continue
3. Topics that should be covered, what's left from O2222, what's on-going from O2222, and other issues that should be addressed
4. Regarding the format of the group
5. Timing aspects that should be considered
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.
[2] Many of these items have been discussed in MISO Stakeholder Forums outside of the DERTF and the MSC, often referring to the DERTF as the forum where detailed work will continue to occur. These items include the modeling issues discussed at the December 2, 2021 Planning Subcommittee meeting; the Parking Lot items included on slides 142 through 143 in the Compliance Framework MISO: items discussed in the September 2021 IPWG discussions on DERA interconnection study requirements and slated for discussion in the IPWG in 2022 (though not yet on the draft Management Plan for that stakeholder forum); the September 13, 2021 meeting focused on coordination with EDCs; and the September 2 MSC meeting, reporting back on the work of the DERTF.
DTE agrees with the majority of stakeholder sentiment expressed at the 1/13/22 DERTF, that there is still value in maintaining regular meetings of the DERTF after the MISO compliance filing is made in April 2022. Extending the life of the DERTF would allow stakeholders to continue to provide critical input on process development, including responses to any FERC requests and ongoing implementation efforts. Such input would not be as effective or efficient if split amongst the other stakeholders entities. MISO should work with stakeholders to amend the DERTF charter for an additional year (to July 2023), at which time additional conversation on the future of the task force can be had.
WPPI’s offers the following feedback on questions re the future of the DERTF:
(1) Should the DER conversations continue at a stand-alone entity at MISO?
(2) For what explicit reasons should a ***stakeholder entity*** continue?
(3) What topics should be covered, what’s left from O2222, what’s on-going from O2222, what other issues should be addressed?
(4) If sought, what format the group should take (TF, WG, or is the proposal from MISO – in that topics are dispersed to other subcommittees or task teams appropriate)?
(5) What timing aspects should be considered?
MJMEUC supports the feedback submitted by MPPA on this issue.
Feedback Request # 1 – Sunset Provisions
During the January 13, 2022 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed its proposal to proceed with the Task Force sunset date as written in the Charter approved by the Steering Committee in May 2021. Stakeholders are invited to provide comments with focus on the following questions:
Please provide feedback by January 24.
The DER Task Force should continue as an entity at MISO even if it doesn’t need to meet every month. If needed, MISO could suspend meetings of the DERTF until after the FERC filing, and then reconvene once FERC responds; but the DERTF should not be sunsetted. There are still significant implementation details that need to be worked out and BPMs that need to be developed. Keeping the DERTF means there will be a forum for stakeholders to continue working through those details. It also provides a means for MISO to address any deficiencies in its filing with stakeholders. If MISO chooses not to continue the DERTF, then a DER Working Group (which would not have a sunset date) could be an effective alternative.
Otter Tail appreciates all that MISO and the DERTF have worked on and accomplished since the DERTF was created in developing a new part of the MISO tariff. In developing this new part of the MISO tariff, the DERTF has identified several items that would benefit from additional discussions. In order to address these items properly, Otter Tail feels that MISO should engage the appropriate forms within its organization to work on these issues.
Environmental Sector feedback on DERTF Sunset Provision
The Environmental Sector appreciates the opportunity to submit comments on MISO’s proposal to proceed with the Distributed Energy Resources Task Force (DERTF) Sunset Provision discussed during the January 13, 2022, meeting. We disagree with MISO’s proposal to retire this entity. The mission set in the DERTF Charter to deliver compliance with FERC Order 2222 is not complete and will not conclude with MISO’s filing with FERC.
We agree with MISO that the scope of the post-filling issues is unknown. However, we are certain that the issues arising post-filing will benefit from this already established Task Force and the community of stakeholders and subject matter experts it convenes. For instance, developing the necessary content to adapt the Business Practice Manual to reflect the implementation of Order 2222 will be an immediate need when FERC accepts MISO’s compliance plan. This need will be addressed in the most effective way through this Task Force. Similarly, coordination needs will arise on issues related to the implementation and operational aspects of the compliance plan that will be best addressed by this dedicated entity.
We recommend MISO review the existing anticipated sunset date of July 31, 2022, and extend it by at least 12 months, acknowledging the ongoing nature of this work and that continued stakeholder engagement will be required. Retiring this entity will result in significant administrative inefficiencies that will cause delays when reconvening on this matter becomes necessary, such delays will be an additional barrier to the delivery of the benefits of Distributed Energy Resource participation in MISO’s markets. This proposal to extend the sunset date aligns with the position of a diverse group stakeholders voiced during the January 13, 2022, DERTF meeting.
Thank you for considering our feedback.
Respectfully submitted this 24th day of January, 2022.
Submitted on behalf of the Environmental Sector.
Guillermo Pereira
Senior Energy Analyst
Union of Concerned Scientists
2 Brattle Square
Cambridge, MA 02138-3780
See attached submittal entitled Feedback of Solarize Indiana, Inc. re DERTF Sunset Provision, dated January 24, 2022.
Consumers Energy appreciates the opportunity to provide feedback regarding MISO's proposal to sunset the Distributed Energy Resources Task Force at the conclusion of the July 2022 date written in the initial Charter.
Consumers Energy supports an ongoing DER conversation continuing at a stand-alone entity at MISO. As stated previously, continuing the DERTF or similar forum/working group for DER related issues will allow ongoing stakeholder discussion and coordination with MISO to identify, prioritize, discuss and resolve parking lot issues, develop and review BPM language, and maintain the forum of DER-focused stakeholders to address related issues outside of the scope of Order 2222 that may surface as DERs continue to be added to the MISO footprint between compliance filing and implementation date and beyond.
Interim topics may include, in addition to items in the compliance framework parking lot:
- stakeholder input that supports development of the future MISO tool for DEAR enrollment and modifications
- development of guidelines for RERRAs and EDCs to consider for technical reviews of aggregations that may help individual states and specific utilities discuss required updates to their tariffs and systems to support DEAR enrollment and timely processing of enrollments and modifications
- explore additional telemetry that may allow an aggregation to participate in providing certain services without ICCP
- further development of operational coordination issues and recommendations between DERA, EDC, LSE/LBA, TO and MISO to support system complexities and communication requirements.
- development of guidelines for consideration regarding interconnection of resources at the distribution level vs. transmission level if a resource could connect to either system
- process, procedures and cost allocation determinations related system upgrades required at D or T level for a proposed aggregation
- details of when MISO and/or TOs are involved in an aggregation enrollment or modification discussion
- Aggregation Dispatch Agent role as discussed within PJM and touched on at November 29 DERTF meeting
- Interim DERA registration and DEAR enrollment related issues or considerations if an aggregation sought participation under existing MISO Resource Types before DEAR Resource Type and enrollment tracking software is created.
- Energy storage resource participation and future DER filings.
- Other issues shared by stakeholders in recent verbal or submitted feedback on this topic.
It would be beneficial if the format of these discussions could continue in a working group format that is not tied to the Order 2222 filing, continuing to address Distributed Energy Resource issues that often cross multiple Main Parent Entity focus areas.
Elimination of the DERTF is likely to delay resolution of DER related issues and lose momentum that MISO will need to be prepared to support its reliability initiatives as the energy landscape continues to evolve. Dispersion of DER topics to other subcommittees is likely result in gaps and receive lower prioritization if different subject matter experts focused on distributed energy resources are not able to attend irregular meetings across multiple main parent entities.
Continuing the DERTF or converting it to a DER-WG provides an appropriate forum for more detailed stakeholder discussions rather than trying to shoehorn portions of this ongoing effort into the limited MSC meetings on the 2022 calendar or scattered throughout multiple MPEs, or sunsetting and losing time and momentum to create a future task team or teams at a later date to address emerging issues months or years later.
Should the DER conversation continue at a stand-alone entity at MISO?
Yes, it is more efficient and effective to keep these issues together in a stand-alone entity.
For what explicit reasons should a stakeholder entity a continue?
Simply stated, a stakeholder entity should continue if there is an expectation that the entity is needed to address issues and if there is support from stakeholders to continue the entity.
What topics should be covered, what's left from O2222, what's on-going from O2222, what other issues should be addressed?
The Parking Lot items that MISO has identified as part of the O2222 stakeholder process to date are a relevant set of issues for the group to address. Other issues will likely come up through the FERC process and as this issue continues to evolve.
If sought, what format the group should take (TF, WG, or is the proposal from MISO - in that topics are dispersed to other subcommittees or task teams appropriate)?
One approach is to continue the group as a TF and evaluate yearly if a continued need for the group exists.
What timing aspects should be considered?
O2222 compliance and implementation is most likely going to take an extended period of time. This could drive the need for a WG to be established at some point.
Clean Grid Alliance Comments to DERTF regarding “Sunset proposal”
January 24, 2021
Clean Grid Alliance appreciates the opportunity to provide feedback on several questions posed to the DERTF at the January 13th discussion on Sunsetting the DERTF. Below are the questions and our responses
Q: Should the DER conversation continue at a stand-alone entity at MISO?
A: Yes, absolutely and at the existing DERTF
Q: For what explicit reasons should a stakeholder entity continue?
A: Because the objectives/tasks in its charter/management plan have not yet been completed, which the DERTF is far from completing its tasks at this point. At a minimum the BPM language that provides the details of implementation of the Order 2222 filing should be complete before consideration of sunsetting this important stakeholder group.
Q: What topics should be covered, what's left from O2222, what's on-going from O2222, what other issues should be addressed?
1) The BPM edits that will cover a majority of the details not contained in Order 2222, as the Order 2222 filing will only provide the framework. Significant heavy lifting is expected with creating BPM content. Having one location to coordinate this effort is necessary and strongly supported by stakeholders.
2) How DER and DEARs impact the transmission system, what metrics will be used, transparency, and the actual process of mitigating impacts. This effort is planned appropriately for discussion at the IPWG, but once completed it should be coordinated with and presented back at the DERTF or in a workshop.
3) DEARs will include LMR. Revisions to LMRs may be needed and should be processed through or at least coordinated with the DERTF
4) Wholesale market distribution access charges. Current tariff policy may require updating. This is best done at the DERTF
5) Distribution billing systems –the RERRAs are responsible for this, but having a forum and coordination to discussing at the DERTF would be valuable.
6) How to ensure reliability at the transmission level when states oversee distribution level policies and utilities have varying control at the distribution level. This will be an ongoing discussion and should be addressed at the DERTF
7) Operational coordination for distributed assets participating in wholesale markets. This topic will be an ongoing discussion for the DERTF.
8) Systems, registration and settlement updates and issues need a forum to live in and be addressed as they come up. The DERTF is the appropriate forum for this.
9) Response and input to the FERC technical conference that was requested, should that request be granted. The DERTF would be helpful for coordination of MISOs participation, if any, in that, and discussion afterward.
10) Transactional energy flows on mesh distribution network connections in a distribution grid. The DERTF was informed last meeting by a stakeholder that this has been a major topic of discussion at the national lab level and among major consulting firms and will definitely need to be addressed to create holistic functional policy.
11) Transparency and how best to implement it for the benefit of both distribution and transmission level interconnection customers. This is a critical point, but not specifically addressed in 2222. Complications exist due to the split in roles and responsibilities between the distribution network and transmission network regulating entities and MISO’s role being limited to transmission system interactions, but this is a critically important topic to collaboratively address, nonetheless.
12) Ongoing monitoring and reporting on what some stakeholders consider a high potential for gaming the system given the proposed removal of the 10MW cap and the lack of transparency on where distribution level interconnections are located, how they are studied, and what reliability impacts they make on the transmission system.
13) Discussion of Xcel’s MN filing on distribution system interconnection and the potential for MISO to create an optional template to assist other distribution companies in moving toward more uniform policies with their neighbors.
14) Monitoring and reporting on load shifting occurring with DERs and DEARs to determine if any adjustments to existing or new policy will be needed to address that.
15) Monitoring and reporting on DER activity and interactions with transmission system that may come up. This is best suited for the DERTF.
16) Adjusting and revising Order 2222 and related BPM policies as more experience is gained and the need arises (which it will).
17) Communications coordination between DEARs, RERRAs, and MISO is still being worked out. A centralized location to address this in general and issues as they come up is needed. The DERTF is best suited for this discussion.
18) Issues that come up in implementation and coordination between MISO and state regulating entities need an ongoing forum to be discussed –the DERTF is well suited to serve this purpose.
Q: If sought, what format should the group should take (TF, WG, or is the proposal from MISO - in that topics are dispersed to other subcommittees or task teams appropriate)?
A: The DERTF would best serve the MISO stakeholders in becoming the DERWG because issues and topics will be ongoing for multiple years at a minimum, and likely ongoing indefinitely, similar to and possibly even more so than the Interconnection Process Working Group.
Q: What timing aspects should be considered?
A: Once FERC makes a ruling, MISO will likely need to move swiftly with a time sensitive response that goes through the stakeholder process. Starting a new stakeholder group, charter, management plan and electing officers takes months, while the DERTF serves exactly the purpose needed and is already set up today. It seems nonsensical to even consider sunsetting it at this point, which is why every comment by the many diverse stakeholders who spoke was very strongly in favor of continuing the DERTF for another year at a minimum. Rarely does such strong consensus occur among MISO stakeholders as was demonstrated at the January 13 meeting on this topic.
To conclude, Clean Grid Alliance strongly supports the recommendation made by multiple stakeholders who commented at the DERTF in support of extending the sunset date by a minimum of 1 year. CGA also supports the state regulators who spoke about the significant responsibilities they carry and the need for a central location to coordinate and discuss topics with MISO, which the DERTF offers and is needed ongoing for that purpose. As detailed in the list above, there is no shortage of topics to address and discuss in the DERTF today, tomorrow, and ongoing. Therefore the DERTF should definitely not be sunset (or even suspended) this year as MISO has proposed, but should be meeting monthly or more frequently at a minimum until the BPM language is complete.
Sincerely,
Rhonda R. Peters, Ph.D.
Technical Consultant for Clean Grid Alliance