MISO is requesting feedback on IBR Performance Requirements
Please provided feedback on the following:
Please provide feedback by March 28, 2023.
DTE appreciates the opportunity to provide feedback on MISO’s proposal to develop performance requirements for Inverter Based Resources (IBR). We commend MISO for being proactive in addressing potential vulnerabilities of the grid driven by increased IBR penetration levels. Developing minimum standards of performance which align with common industry practices will aid in the transformation in the generation fleet. DTE does however have several concerns that we’d like MISO to contemplate as we move forward which include:
1) the lack of compensation for reliability services,
2) transition plan for manufacturers to modify equipment and
3) compatibility of software (PSSE) with proposed performance requirements.
The elimination of the reactive power compensation has removed the incentive from Market Participants to provide reactive power which could impact grid reliability as IBR growth continues. We urge MISO as it work through this process to address the void in reactive power supply caused by the recent changes in Schedule 2. Additionally, we encourage MISO to consider the rate in which manufacturers will be able to modify their equipment as the implementation plan is developed. A plan that does not consider the reality of manufacturer capabilities will be hindered by supply chain deficiencies as manufacturers work towards compliance. Finally, MISO will need to ensure that their software tools are compatible with the new performance standards so that the stability studies can reflect these changes. For example, will the standard libraries provided by the software have the facility to enter all of the parameters necessary as listed in the standards developed by IEEE. If not, there is a risk that vendor proprietary models will not be ready in time or it may be difficult to use a large variety of these proprietary models in a dynamic study.