MSC: Strawman Proposal to Require Separate Market Participation by Resource Type (MSC-2020-2) (20230302)

We would suggest that this be an option for Market Participants and not an obligation.  There are numerous combinations of resources that could make up these sites and this is not a one size fits all proposal.  As long as the Market Participant does not exceed the Generation Interconnect, they should be allowed to register, or not register the facility as they see fit.

As an example, a solar farm that is combined with battery storage would be very different from a solar farm combined with a combustion turbine.  The solar and battery is limited by the duration of the battery, the solar output capability and the requirement to recharge the battery.  In contrast, a solar farm combined with a combustion turbine would be able to maintain full capability at all times.  At times when the combination of the two could exceed the generation interconnect, the combustion turbine could limit its output to match the requested output.

This second combination is also more efficient for the system and prevents overbuilding.  The transmission system for a solar facility has to be built for the maximum output for the facility even though it only has a limited capacity factor.  In contrast, a solar and gas combination transmission system can be built for a facility that can produce at full capability at any time and still provide solar output when capable and the higher cost resource is not needed.

Thanks for considering.

ITC supports MISO’s proposal to ensure that resources are modeled and dispatched at the most granular level possible. More granular transparency supports operators being able to understand resource dispatch performance more fully.  Dispatch at this more granular level should be coupled with individual resource ICCP and metering requirements (not measurement and verification but actual real time measured metering by interval) to ensure that the energy supplied at the Point of Interconnection (POI) is attributed to the correct resource. 

ITC also supports MISO moving forward to ensure that output of co-located resources (and hybrid resources if that designation is retained) is limited to the level agreed upon in the GIA. Further, we encourage MISO to implement this capability for all registered Resources.

 MISO development of dispatch optimization for co-located Resources (Resources at same POI with distinct offer curves for each resource behind the POI), appears to be forward looking. This capability would enable MISO to see further into the system and this capability could potentially be used to dispatch more granularly, overall. MISO may want to evaluate potential interactions with this proposal and the multi configuration system capability for combined cycle resources, as well as ramifications for system development for Order 2222 implementation. Further, if MISO will be allowing generators at the same bus to swap generation as is out for comment at this time (in a separate comment process) this appears to interact with this proposal for granular dispatch.  If MISO is indifferent to which resource is actually supplying the energy at the POI, there is an argument to be made for hybrid. If this is not the case, we suggest that the replacement energy at the same POI be subject to the granular offer curve, ICCP and metering requirements as suggested above.

MidAmerican appreciates the opportunity to provide feedback on the Strawman Proposal to Require Separate Market Participation by Resource Type. (MSC-2020-2) (20230302)

MidAmerican supports MISO’s suggestion to have separate. co-located resources with separate CPNodes when dealing with a hybrid arrangement where two or more resources are sharing an interconnection limit. MidAmerican would just ask that MISO provide clear guidance on how these separate units are to be offered. For example, if a 300 MW wind farm and a 300 MW natural gas combustion turbine are sharing an interconnection of 500 MWs, the day ahead offer for the wind farm would likely be the wind forecast for the wind farm. What should the offer for the combustion turbine look like, especially when the wind farm is forecasted to be over 200 MWs and more importantly, what will the real time offer look like? What if the combustion turbine has a minimum of 10 MWs? MISO should provide a very clear example using an intermittent resource and a controllable resource and explain what they are expecting to see for day ahead and real time offers and must offer requirements. MISO may also want to consider having the ability to update unit limits via .xml. This guidance should include emergency values as well.

For emergency offers during EEA events, MISO may want to consider whether combined generation output exceeding the hybrid or surplus interconnection limit would be acceptable to some extent, subject to review of equipment capabilities by the transmission owner, stability limits and other relevant authorizations by MISO. MidAmerican understands that other independent system operators may allow certain interconnection limit exceedances for EEA events, in cases where hybrid or surplus interconnection is utilized.

Clean Grid Alliance Comments to the MSC on a Hybrid Co-Located Participation Model
March 16, 2023 

Clean Grid Alliance (CGA) greatly appreciates MISO’s effort to address the gap in a market participation model for hybrid resources that meets the need for DIRs to be on the MISO forecast while also meeting the need for storage to be able to charge. With thousands of megawatts of hybrids (both as hybrids and individual components) going through the Generator Interconnection process, the need is urgent. We believe the co-located model has merit, and with a few clarifications and possibly refinements, could potentially help fill the gap that currently exists. 

A primary consideration we have is the Capacity Accreditation of Hybrid resources. While this proposal does not address it directly, the interaction of this proposal with Capacity Accreditation needs to be better understood by stakeholders and hybrid components should seemingly be able to elect to combine into a single entity for Capacity Accreditation, regardless of the Market Participation models the individual components are registered under. Please confirm that this will be case and that the individual components will not be required to have separate accreditation at the end of the day. 

MISO currently requires storage resources to obtain very costly transmission service to charge from the grid, in addition to "battery charging" studies required in the interconnection process. Please confirm that when a co-located battery is charging from its hybrid counterpart of wind, solar, etc, at the same POI, no transmission service charges will accrue. If transmission service for charging between co-located resources was required as part of this proposal, Clean Grid Alliance would not be able to support it. 

While MISO has indicated that it will not initially optimize individual offers at a shared Point of Interconnection (POI) to ensure injection limits are respected, we would like to understand how combined or coordinated offers can be made by parties to achieve this objective. Additional information or possibly a tutorial on how to accomplish this would be very helpful for stakeholders. Some concerns have been raised that managing a single POI is much different than precisely managing two components, as individual units would be constrained to their cleared schedules individually, and not in aggregate. Furthermore, units in a hybrid, vs co-located configuration, may not be operated the same. When there is storage plus wind or solar and the sum of the MW’s of the parts exceeds the injection limit (which should be just about always for most hybrids that are built), then the need exists for flexibility for the internal components to “help each other out” to get better performance to meet an objective, whether that is following dispatch or maximizing capacity value. If each component is a separate CPNode and separate settlement meter, and if the output of the components is limited ex ante through offers, there is no flexibility in real time to perform better than the worst of the forecasts/offers. Therefore, MISO management of the POI would seemingly be an extremely important element of this proposal, and we look forward to information on the timing needed for implementation of that capability.

As part of this process, we would appreciate clarification on the definition of “shared interconnection”. For the purposes of co-located resources, what equipment would be shared, and are there any differences between facilities with a Shared Facilities Consent Agreement, and facilities with separate Interconnection Requests? For example, if there are two facilities with two separate IRs that share a switching station but have separate GSUs, can those two facilities have a single IA or two separate IAs? For facilities that have two separate IAs are there any differences that need to be accounted for between those with a single GIA? 

Finally, antitrust concerns regarding coordinated offers were brought up by stakeholders at the MSC meeting, and we look forward to MISO’s response on how to best resolve or address those. 

Again, we appreciate MISO’s effort on this timely topic and look forward to additional information. 

Sincerely,

Rhonda Peters, Ph.D.

On Behalf of Clean Grid Alliance

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Market Sub-Committee (“MSC”) on the feedback request made by MISO at the March 2, 2023, meeting of the MSC.[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.

At the March 2^nd meeting of the MSC, MISO presented their straw proposal for hybrid resources to “be required to register and participate separately in the market by Resource type.”[3]

MISO requested feedback on support or objections to the straw proposal. AEMA offers the following comments:

• Benefits of Separate Participation: AEMA appreciates and supports MISO’s proposal to clarify Tariff language on Hybrid and Co-Located Resource Market Participation and provide a mechanism for market participation. The ability to combine groups of resources into similar participation models creates a valuable option for Market Participants that will serve certain situations very well; however, this option is not the most efficient for all situations. 
• Require Versus Option: AEMA is concerned with MISO’s use of the word “require.” MISO should allow resources the option to register and participate separately by Resource Type but should not require this separation. A Market Participant that can operate multiple types of resources in a coordinated fashion to meet the performance requirements of any MISO Market Participation Model should be allowed the option to do so. For example, a Market Participant with Solar and Battery resources that desires to register and participate as a single resource should be allowed to do so. It should be the Market Participant that decides the most efficient and effective participation model of hybrid or co-located resources. AEMA requests that MISO adjust the language of their proposal to clarify that separate participation models are an option and not a requirement.
• Hybrid Participation Models Promote Balanced Markets: Hybrid participation models, which can be an aggregation of multiple technology types, are a key element of well-functioning markets. FERC Order 2222, notes that “…some individual resources or certain technologies may not be able to meet the qualification or performance requirements to provide certain services to RTO/ISO markets on their own, they may be able to satisfy such requirements as part of a distributed energy resources aggregation where resources complement one another’s capabilities.”[4] While Order 2222 is targeted at distribution level resources, the same principle applies to any jointly located resource that may be able to more efficiently participate in the MISO market through a combined participation model. In its Order, FERC requires RTO/ISOs to ensure different technology types are able to participate in a single aggregation.[5] MISO should allow the option for combining resource types to a single hybrid participation model at all levels of interconnection. 
• Order 2222 Implications: In its proposal, MISO mentions that “a well-functioning co-located participation model may obviate the need for a new/additional hybrid resource participation model.”[6] AEMA would request MISO to reconsider this statement considering the impact to the proposed participation model for MISO’s compliance to FERC Order 2222 on allowing aggregation of Distributed Energy Resources (DER). In its pending Tariff filing, MISO has proposed to create a new resource type that functions as a hybrid resource participation model, that would allow for combinations of resource types into a single participation model. AEMA would request that MISO review the proposed DER participation model that is to be developed upon FERC approval of the Order 2222 compliance filing and create a similar model for all hybrid resources. From initial review, it appears that the March 2^nd proposal from MISO to require separate participation models may be at odds with the Order 2222 compliance proposal, which will create a new participation model for different resource types.
• Visibility and Efficiency: MISO suggests that the proposal will “maximize visibility, efficiency, and value for Market Participants and MISO.”[7] AEMA disagrees with statement that this proposal maximizes these characteristics. In fact, the requirement for the separation of resources will be inefficient and potentially destroy value for aggregators of resource types that might find more efficiency in coordinating different types of resources in a single participation model. The opportunity to understand how hybrid resources would perform in the market would also be lost by making modeling of separate resource types a requirement and not pursuing a hybrid participation model. Although the aggregation into a hybrid model can be complex, the complexities are the responsibilities of the Market Participant. So long as the Market Participant meets the performance requirements established by MISO for a resource type, then the hybrid aggregations should be allowed to participate as that type of resource. For these reasons, AEMA requests that MISO change their straw proposal to allow both separation by resource types, modeling of hybrid resources in any existing participation model, and to explore single hybrid model.

AEMA appreciates MISO’s consideration of these comments as part of the examination of resource modeling issues within MISO. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to discuss this with AEMA members. 

Respectfully Submitted, 

Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aem-alliance.org
202-524-8832

 or

DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052

WPPI offers the following feedback on MISO’s proposal to require each Resource Type comprising a Hybrid Resource to participate separately (aka co-located) in MISO:

(1)    Feedback request: “Support or any objections to the proposal including necessary detail, analysis and any proposed resolution”

• WPPI does not support requiring a Hybrid Resource participate as co-located (vs. also having the option to participate as a “true” Hybrid Resource using the existing models previously discussed, e.g., 6/21/2021 Hybrid Resources – Market Participant Workshop).

–   To the extent a Market Participant agrees with MISO that it is preferable for a Hybrid Resource to participate as co-located vs. as a true Hybrid Resource, the Market Participant will chose co-located.

–   WPPI did not find any basis in MISO’s 3/2 MSC presentation to eliminate the option to participate as a true Hybrid Resource. In addition, we understand some have antitrust concerns in the case of co-located Resources with different Market Participants and the need for them to manage (because currently MISO systems cannot) the interconnection MW limit through the offers of their co-located Resources.

(2)    Feedback request: “Any suggestions to improve the proposal including detailed rationale and underlying issues”

• It appears to WPPI that the only reason for a Hybrid Resource to participate as a true Hybrid Resource vs. co-located would be to manage the interconnection MW limit through a single offer vs. through multiple offers (one for each Resource). Therefore, before considering eliminating the true Hybrid Resource participation model options, it seems necessary that the MISO systems be able to optimize use of the interconnection MW based on the offers of the co-located Resources. MISO’s 3/2 presentation (see specific references below) and the discussion at the meeting suggested this is very doable and WPPI recommends MISO make it a high priority.

–   s. 12 “Some relatively small technology changes may be made to maximize value of multiple Resources that share interconnection”

–   s. 14 “(potential future)” software enhancement to create a “family” relationship for co-located Resources to efficiently manage a shared interconnection limit between Resources”

Michigan Public Power Agency supports WPPI’s feedback below:

1. Feedback request: “Support or any objections to the proposal including necessary detail, analysis and any proposed resolution”

• WPPI does not support requiring a Hybrid Resource participate as co-located (vs. also having the option to participate as a “true” Hybrid Resource using the existing models previously discussed, e.g., 6/21/2021 Hybrid Resources – Market Participant Workshop).
• To the extent a Market Participant agrees with MISO that it is preferable for a Hybrid Resource to participate as co-located vs. as a true Hybrid Resource, the Market Participate will chose co-located.
• WPPI did not find any basis in MISO’s 3/2 MSC presentation to eliminate the option to participate as a true Hybrid. In addition, we understand some have antitrust concerns in the case of co-located Resources with different Market Participants and the need for them to manage (because currently MISO systems cannot) the interconnection MW limit through the offers of their co-located Resources.  

1. Feedback request: “Any suggestions to improve the proposal including detailed rationale and underlying issues”

• It appears to WPPI that the only reason for a Hybrid Resource to participate as a true Hybrid Resource vs. co-located would be to manage the interconnection MW limit through a single offer vs. through multiple offers (one for each Resource). Therefore, before considering eliminating the true Hybrid resource participation model options, it seems necessary that the MISO systems be able to optimize use of the interconnection MW based on the offers of the co-located Resources. MISO’s 3/2 presentation (see specific references below) and the discussion at the meeting suggested this is very doable and WPPI suggests MISO make it a high priority.
• s. 12 “Some relatively small technology changes may be made to maximize value of multiple Resources that share interconnection”
• s. 14 “(potential future) software enhancement to create a “family” relationship for co-located Resources to efficiently manage a shared interconnection limit between Resources”

Wolverine Power Cooperative supports MISO’s proposal so long as MISO prioritizes, as WPPI requests, the software changes to accommodate.

•  s. 12 “Some relatively small technology changes may be made to maximize value of multiple Resources that share interconnection”
•  s. 14 “(potential future)” software enhancement to create a “family” relationship for co-located Resources to efficiently manage a shared interconnection limit between Resources”

The Entergy Operating Companies (“EOCs”)[1] submit the following comments for MISO’s consideration regarding hybrid participation. The Entergy Operating Companies have potentially significant concerns with MISO’s proposal to require hybrid resources to participate separately, and would request that MISO take reasonable steps to address those concerns.  These concerns include: concerns about the unreasonable burden of requiring compliance by pre-existing hybrid resources, interconnection issues, and larger policy issues around technology.

First, if a hybrid unit was already planned, developed, and placed in service based on the current MISO rules, it should be exempt from any new rules related to interconnection.  The construction costs required to reconfigure existing resources to allow them to participate in the market consistent with this new requirement are unreasonably and significantly burdensome, and an existing resource had no notice of or opportunity to comply with the new rules during its development. Therefore, if this proposal is adopted, existing resources already in service should be grandfathered and not required to comply. 

Second, it appears as if the proposed new required configuration would present interconnection issues.  For example, if a resource was designed and built to charge the battery from the solar panels rather than from the grid, how would MISO or the Market Participant monitor the two, now separate, resources to ensure the applicable interconnection limit for the resource is not exceeded?

Lastly, it appears MISO’s proposal would unreasonably disqualify an available technology, DC interconnected systems, entirely.  DC interconnected systems harvest unused or excess DC power that all solar sites have, generally in the mid-day time, and store that in the battery for use later on. For MISO to tout the tremendous role battery storage will have in the future market, while disqualifying hybrid battery resources that use DC interconnected systems to unlock the most benefits for battery storage, is arbitrary and unreasonable – and suboptimal. 

The EOCs would welcome the opportunity to discuss these concerns with MISO in an individual meeting and/or at a future MSC meeting.

Feedback by Public Service Commission of Wisconsin (PSC) Office of Regional Markets (ORM) Staff to Midcontinent Independent System Operator (MISO) on the Reliability-Based Demand Curve (RBDC) proposal. 

The presentation at the Market subcommittee laid out the advantages of having Hybrid resources registering in the marketplace as co-located resources (two or more resources sharing an interconnection and registering as separate nodes). What are scenarios where having two co-located resources registered under this proposal would have a negative impact on the market or certain participants, and what would their effect be? Are there any advantages to having one registrant for two resources per interconnection over separate market registrations as proposed? We appreciate the opportunity to provide feedback on this issue.

• Minnesota Power agrees with the general direction of having Hybrid resources registering and participating separately in the market by Resource type.
• With each resource type participating in the market separately, MISO will need to have systems in place so that it does not send dispatch signals to the two resources that total more than the hybrid’s approved interconnection limit?
• The operator of the hybrid facility needs the flexibility to control the individual resources as needed to meet the total energy requirement from the facility without incurring MISO penalties on both resources.
• Minnesota Power is also concerned about the doubling up of MISO charges for each resource type, and believes that consideration needs to be made to avoid excessive MISO charges.