IPWG: MISO DER Affected System Proposals (20221010)

Entergy Operating Company Feedback to the IPWG on MISO’s DER Affected System Proposal

October 24, 2022

The Entergy Operating Companies[1] (Entergy) provide the following feedback to MISO on the DER Affected System Proposal elements discussed at the October 10, 2022 meeting of the Interconnection Process Working Group (IPWG).  

MISO has requested that Stakeholder provide feedback on the following aspects of the Affected System Study Process:

• Extending the deposit submittal timeframe to be up to 30 days
• Information proposed for the public and confidential reports
• Report delivery process, including 10-day comment period

Entergy’s feedback is at a higher level of detail than the aspects of MISO’s proposal on which feedback has been requested.   Entergy agrees that the Transmission Owner (TO) and MISO have primary responsibility for evaluating the impact of DERs on the Transmission System, and MISO and Transmission Owners are similarly situated relative to visibility into Distributed Energy and Demand Response Resources that have the potential to impact the Transmission System, in that both MISO and Transmission Owners depend on the Electric Distribution Company (EDC), Distribution Provider (DP), or Load Serving Entity (LSE), to communicate the information that is necessary to evaluate these impacts. 

MISO’s proposal requires that resources impacting load behind the meter be tracked for their cumulative potential to impact the transmission assets on the Bulk Electric System side of substations under MISO’s Functional Control.  Entergy believes that as the entities with commercial and regulatory relationships with distribution sited resource owners, LSEs/EDCs/DPs are the entities that will ultimately track the information need by the Transmission Owner/Planner and MISO for evaluation.  Therefore, Entergy believes that the responsibility for collecting Affected System Study Funds should be assigned to the LSEs/EDCs/DPs, and that this approach would be more consistent with the responsibilities outlined in MISO’s MOD-032 Manual. 

Also regarding MISO’s MOD-032 Manual, Entergy notes that there is a growing importance to updating the entity registration designations in the Manual for consistency with NERC-defined Registered Entities, and rules related to DER reporting provide the most relevant examples of the need for this Manual to be updated.

Finally, MISO noted at the October meeting of the IPWG that these DER Affected System Studies will not be coordinated with DPP study cycles.  Entergy understands that such coordination will be difficult but encourages MISO to document how the sequencing of studies and allocation of any network upgrades resulting from these studies that impact an ongoing study will occur going forward, in order to avoid unnecessary dispute over the assignment of Network Upgrades.

The Entergy Operating Companies appreciate the opportunity to comment on changes to this important process.

Azimuth is grateful for the opportunity to comment.

Azimuth encourages MISO to revisit its initial questions regarding DER distribution tariffs by seeking direct stakeholder feedback regarding distribution interconnection tariff process, timelines, and fees across its footprint. MISO astutely asked how DER distribution tariffs should be integrated into the DER Affected Systems study proposal but did not seek formal stakeholder feedback. Such feedback is highly relevant to the current feedback request.

Azimuth respects and appreciates that TOs and/or EDCs will need sufficient time to collect deposits from multiple DER customers and submit deposits to MISO. However, from a DER interconnection customer perspective, extension of administrative time frames beyond what is in current local rules adds time and cost. Layering in proposed MISO requirements into current RERRA/LSE/EDC level requirements could mitigate or even eliminate delays.

MISO’s proposal that entities paying for interconnection studies should have full access to results with proper confidentiality agreements is sound. DER customers making up more than 10% of the total DER MW injection being studied should have access to disaggregated results relevant to a distribution interconnection customer’s particular project.

Azimuth appreciates that MISO is proposing a comment period. Sufficient notice should be given to parties to prepare for a comment period. Additionally, all parties involved should have the option to elect to have access to comments and responses from MISO and other stakeholders with proper confidentiality agreements.

MISO raised the issue of cost sharing between DER Affected Systems and the DPP study projects in the latest IPWG meeting and ultimately decided not to pursue developing a cost sharing mechanism. Azimuth would appreciate more information on how MISO determined that cost sharing is not justified by the current need. What information is MISO using to scope the current need?

Thank you for the opportunity to comment.

American Municipal Power (AMP) appreciates the opportunity to provide feedback on the MISO DER Affected System Proposals.

In MISO’s presentation to the Interconnection Process Working Group on October 10, 2022, it is stated on slide 13 that MISO’s DER Affected System Study results will be at the substation level, and that the entity responsible for managing the RERRA interconnection process, typically the EDC, would be responsible for disaggregating the results. AMP is requesting that MISO provide further explanation and details on how this process would be managed and what MISO means by “responsible for.”  For example, AMP would oppose MISO assigning cost responsibility to the EDC and or RERRA who would then need to seek cost recovery from the resource owners or entities managing the DER aggregate’s participation in the MISO markets.

AMP does not have any comments on the other requested items at this time.

ITC thanks MISO for the opportunity to comment on the IPWG: MISO DER Affected System Proposals (20221010) 

In MISO’s proposal you have identified that the TOs should identify all substations that have a net injection onto the transmission system, distribution system load minus DER.  This creates a problem for the transmission owners who are not in a position to know where this is or may occur.  In essence, MISO is telling the TO they are likely an “affected entity” and to go out find where this is occurring and who is “affecting”.   The Distribution Providers will know the amount of their load and the location and type of the DER entities thus will be the only entity able to identify to both MISO and the TO the locations where an injection would potentially occur.  They will also be the only entity able to identify those DER entities who will be grandfathered  prior to the start of MISO’s process.  Neither MISO nor the TO will have a record of who these DER entities are.  MISO has an existing MOD-032 process that request the Distribution Provider (LSE) enter their DER entity technical data into the transmission system model when they enter their load information.  This portion of the process, requesting this technical data, needs to be re-written so that MISO is able to get the DER data, both they and the TO, need from the Distribution Provider as they are the source that has the information today and will always be the best source for the data.

The timelines MISO is identifying appear to only have the potential of being possible if MISO starts the process through working with the Distribution Providers (LSEs) instead of insisting on mandating a process that places the TOs in a position of looking for where they may be an affected party.  Adding unnecessary processes between each TO and DP to identify where they may be and affected party will affect MISO’s desired timelines and processes as these will be different based on each TO and DP.

As for the payment of the fees MISO is looking for by location, MISO again needs to look to the entities closest to the DER entities to administer their fee not the transmission entities.  This would be the Distribution Providers.  While working with the distribution Providers causes MISO to work with a larger pool of entities, there are good reasons for doing so which include:  better data and faster response.  Through working with the Distribution Providers MISO may be able to meet its 30 day time horizon.  This will most likely not be possible working through the TOs due to the additional handling required of the both the billing and the payments.

The Coalition for Community Solar Access (“CCSA”) appreciates the opportunity to provide feedback on the MISO proposal discussed at the October 10 working group meeting. 

CCSA is a national coalition of businesses and non-profits working to expand customer choice and access to solar for all American households and businesses through shared solar programs. CCSA’s mission is to empower every American energy consumer with the option to choose local, clean, and affordable shared solar. CCSA is composed of over 100 member companies and non-profits working together to expand access to clean, local, and affordable energy. The members and staff of CCSA have experience working in different states under different community solar policy models.

As a general matter, CCSA is concerned that the MISO DER Affected Systems study proposal could have significant and far-reaching negative impacts on community solar project development in at least two ways. First, nothing in the proposal appears to provide an exemption to projects based on their maturity. A project that already has a signed interconnection agreement and has begun construction could thus be subject to a DER Affected Systems study, resulting in significant disruption or cancellation due to unpredictable extensions of project timelines and added costs. Second, the proposal does not appear to allow time to ensure proper coordination and preparation at the state and utility level. Given the multi-party, multi-jurisdictional nature of the proposal and the information exchange required, implementing it too quickly could result in widespread delays to processing of interconnection applications. 

To mitigate untenable impacts to project development, CCSA urges MISO to do the following: 

1. Develop a multi-jurisdictional implementation roadmap and timeline that provides sufficient notice to local utilities, state regulators, and DER companies before making a finalized DER Affected Systems study process effective. The proposed approach presents several coordination challenges and need for additional time to ensure effective implementation of process changes. Some of these challenges include the need to adjust local interconnection rules at state commissions, as MISO has previously noted. State commissions may also wish to issue guidance on the processes that distribution companies subject to their regulation must follow when communicating to interconnecting applicants. CCSA agrees with Azimuth Renewables’ assessment, in comments submitted on September 20, 2022, that an 18-month notice period will allow sufficient time for stakeholders to adjust regulations and business processes.   
   
   
2. Immediately provide and maintain a list of all substations that have been screened to-date, and indication of whether they have passed/failed each screen in addition to ongoing reporting requirements described in response to question 4 below. Such information is critical for developers seeking to understand impacts to current or future projects in development within the MISO footprint. 
   
   
3. Within one year after the initial implementation of the DER Affected Systems study process, commit to conducting a process review, including soliciting stakeholder feedback on progress and challenges. CCSA recommends building in a feedback mechanism considering the limited engagement from DER industry stakeholders in the discussion of the DER Affected Systems study proposal to date. 

In addition, CCSA respectfully submits the following responses to specific feedback requested by MISO during the October 10 meeting.

1. Extending the deposit submittal timeframe to be up to 30 days 

CCSA does not oppose increasing the study deposit submittal timeframe to 30 business days if it increases the likelihood that the overall process timeframe will be adhered to. 

As noted above, CCSA seeks timeline certainty in this proposal and urges MISO to take steps to ensure the DER Affected Systems study process reflects realistic timeframes. We recognize that this stakeholder process is one of the ways in which MISO is working to create realistic timeframes, but we note that DER developers require greater timeline certainty than the proposal currently contains. Key stakeholders have highlighted the unrealistic nature of the timeline as currently proposed. (For example ITC Holdings stated in comments submitted September 9, 2022 that “120 days or more [emphasis added] should be explored.”) As noted in CCSA’s general comments above, as an initial mitigation measure, MISO should provide at least eighteen months’ notice to local utilities, state regulators, and DER companies before making a finalized DER Affected Systems process change effective. 

2. Information proposed for the public and confidential reports 

CCSA agrees that there should be a public report and information options that are accessible to DER Customers and provide insight into scope, timeline, or cost impacts to their project. This is a common practice in other states that have adopted similar approaches to the one under consideration by MISO. For example, utilities in Maine, Massachusetts, and Rhode Island host ASO-related information on their respective websites linked below. 

• National Grid (MA): https://ngus.force.com/s/article/MA-ASO-Updates

• PPL (RI): https://ngus.force.com/s/article/RI-DG-Group-Transmission-Study-Update

• Avangrid (ME): https://www.cmpco.com/wps/portal/cmp/networksfooter/suppliersandpartners/servicesandresources/interconnection/

CCSA requests clarification as to how stakeholders might access reports that contain Critical Energy Infrastructure Information (CEII). DER customers that pay for this analysis should have a vehicle to access the information, subject to the appropriate NDA (with the MISO and/or TO). We note that other jurisdictions have made reports available to stakeholders with CEII clearance.  For example, ISO New England reviews ASO reports submitted by New England Transmission Owners in the Northeast; these reports are made available to stakeholders with appropriate clearance. Additionally, Central Maine Power makes interim information available to DER developers with CEII clearance over the course of the study period (i.e., after steady state completion).

3. Report delivery process, including 10-day comment period
   

CCSA supports extending the report delivery process timeframe and suggests that a 15-business day comment period is more reasonable for iterative comments and feedback. CCSA requests clarification that the comment period begins upon delivery of the report to the DER Customer by the EDC/TO. Additionally, CCSA requests clarification of what process is utilized and what entities are responsible for report approval.

4. Priority DER screening and study tracking information 

As noted above, CCSA urges MISO to ensure that stakeholders have timely access to data on the screening results for substations in MISO territory.  CCSA requests that the following information be made available as soon as possible and that it be updated on a monthly basis: 

1. Substation Name

2. Transmission Owner

3. Total Connected DG 

4. Total Pending DG

5. Date of last MISO Screen

1. (a) 1% Screen (Pass/Fail)

2. (b) Aggregate Screen (Pass/Fail)

6. Completed ASO Study (Y/N)

7. Upgrades Identified (Y/N)

8. Ongoing ASO Study (Y/N)

9. Total Pending DG in MISO ASO Study

10. Additional information such as electrical dependencies