In the August 8, 2023, meeting of the Interconnection Process Working Group (IPWG)stakeholders were invited to review and submit feedback on Proposed IBR Performance Requirements.
Please provide feedback by August 29, 2023.
Transmission Owner Feedback on Proposed IBR Performance Requirements
August 29, 2023
In the August 8, 2023, meeting of the IPWG, MISO presented Proposed IBR Performance Requirements and requested:
The MISO Transmission Owners (Owners or TOs) provide the comments below for MISO’s consideration.
Regarding the feasibility of Interconnection Customer equipment being allowed at POI substations to further inform Reference Point of Applicability (PRA) at POI proposed
MISO’s August 8 IBR Performance Requirements presentation to the IPWG (slide 16) suggests that there is some flexibility in determining compliance with NERC Standard PRC-024-3. However, PRC-024-3 Requirement 2 clearly requires that voltage ride through of applicable Generator Owner voltage protection is to be evaluated for the voltage excursion curves defined in Attachment 2 “at the high-side of the GSU or MPT.”
The Owners are opposed to any requirement for IC equipment to be installed at the POI substation. The separation of IC and TO equipment aligns with many Transmission Owners’ physical and cyber security policies and eliminates the need for the IC to coordinate with the TO to gain access to IC equipment in the TO substation for construction, operation, and maintenance activities.
General comments regarding MISO’s proposed approach:
Recognizing that that NERC is also working on IBR standards, and these standards are supplemental to IEEE, which are evolving, the Owners appreciate MISO’s proposed language indicating that TO criteria that is more prescriptive would supersede, and that is an important aspect of MISO’s requirements that the Owners support.
Regarding the proposed Tariff Revisions:
The Owners request that MISO revise the final paragraph in the Tariff redlines to include GIAs signed “or amended with inverter changes” on or after January 1, 2025 are not eligible for requirement exception to read
If the performance or capability exception can be mitigated through equipment firmware upgrades still under development, the Interconnection Customer shall implement the firmware upgrade within sixty (60) calendar days of commercial availability of such firmware. GIAs signed or amended with inverter changes on or after January 1, 2025, are not eligible for requirement exceptions. Further, the process for establishing exceptions shall not apply beyond the DPP-2022-Cycle.
This addition will treat all Interconnection Customers the same after the cutoff date.
Invenergy thanks MISO for the opportunity to provide further comments on MISO’s proposed IBR performance requirements. Invenergy appreciates the responses MISO provided to the initial round of stakeholder feedback and provides the follow-up feedback below:
Industry Readiness: Invenergy appreciates MISO’s industry outreach and emphasizes that industry readiness will be the greatest challenge for IEEE 2800 standard implementation. Invenergy sympathizes with MISO’s search for a complete picture of industry capabilities. Invenergy urges MISO to present the diligence which supports the feasibility of IEEE-2800 implementation to stakeholders prior to filing the proposed changes to FERC. Any compliance timeline which is disconnected from market realities will result in further interconnection delays and drive project cost uncertainty.
Impact to Timeline: In the response to June feedback, MISO stated that there has not been analysis done to identify “interdependencies between queue reform and IEEE 2800 adoption related to costs and timelines.” Invenergy would highly recommend that MISO conduct preliminary analysis to understand potential queue implications for the proposed requirements. Especially in the context of a queue seeing historic levels of uncertainty (FERC Order 2023, unprecedented size and demand for renewables, DPP22 delay and upcoming reform), successful adoption of the standards requires some consideration of unique queue conditions.
Implementation for DPP22: Invenergy agrees with MISO’s response to June feedback regarding retroactive implementation, which notes that retroactive implementation of the IEEE standards would be difficult and burdensome. Invenergy also appreciates the level of flexibility MISO is proposing to grant DPP22 projects. However, Invenergy would ask MISO to reconsider the costs and benefits of premature implementation of the proposed requirements. Supply contracts require long lead times and changes to hardware or software requirements can have far-reaching timeline impacts. Requiring paperwork for DPP22 projects to prove exemptions may only exacerbate project delays.
Cost Impact: In responding to cost-based concerns, MISO shared a “sense” that the proposal will not generally increase costs, as most changes involve software code. Invenergy urges MISO to evaluate whether this sense holds up in implementation, as Invenergy is aware of several circumstances in MISO’s proposed changes which may require hardware changes. For example, any existing resources which may not have the measuring capability to capture high voltages (7.2.3 transient overvoltage) would require a hardware change. Determining the appropriate timeline for implementation requires an analysis into potential supply and cost impacts.
Compliance: MISO responded to stakeholder concern regarding compliance testing by stating that MISO does not intend to use IEEE 2800.2 standards for compliance and that test procedures in BPM-015 could be customized to test for compliance. Invenergy would ask MISO to elaborate on how these test procedures could be amended. Such information would be helpful in assessing the extent to which existing resource models need to be modified to comply with MISO’s proposed standards.
Invenergy thanks MISO staff for their efforts and looks forward to continued collaboration.
Pine Gate Renewables appreciates the opportunity to provide comments on this issue. We echo the concerns raised by NextEra, Invenergy, and the TO Sector regarding setting the RPA at the POI, which were presented in the feedback summary at the August 1 IPWG. Specifically, installing and managing equipment by a Generator Owner (GO) on a Transmission Owner (TO) substation will complicate engineering and operations on both sides. The TO Sector made a valid comment that asking the GO to evaluate voltage and frequency ride-through at both the POM for PRC-024 compliance and the POI for IEEE 2800 compliance is overly burdensome and unnecessary. NextEra also highlighted the note in IEEE 2800 that using the POI may or may not be feasible if the GO cannot install equipment on the POI substation. We ask MISO to carefully consider how this will get implemented, and to not leave it for GOs and TOs to figure out in the engineering design of each project.
WPPI offers the following comments on the draft changes to Appendix G. In addition, we submit via email a red-line version with comments and suggested edits. We are not familiar with the IEEE standard in question and thus there may be reasonable MISO responses to the points we raise, based on information we are not aware of. IEEE 2800-2022 is a proprietary, non-public standard. As a threshold issue we question the appropriateness of relying on such a standard in tariff language, though perhaps this is an approach with precedent in MISO processes. Based on review of public elements of the standard, it appears that it refers simply to IBR, and not to ‘IBR plants’—which is a term MISO adopts in the proposed changes (though not in the first sentence under Section A -General). We would suggest that MISO simply refer to IBR (singular or plural) and dispense with ‘plant(s)’, which appears unnecessary and awkward, to the extent this does not mirror terminology in the referenced IEEE standard. |
Please see further comments in separately submitted red-line version.