MUG MISO Planning Modeling Manual Feedback (20230613)

For new proposed language in section 4.4.4.2 (Wind Farms) and 4.4.4.3 (Solar Farms), make clear that the unit status is offline (0) and shunt status is online (1), otherwise shunt status should be offline (0).

For new proposed language in section 5.6 (Distributed Energy Resources), does this section apply only to IBR DERs?  Are there any other qualifiers that can be added here?  ATC suggests a MW threshold of 5 MW for getting dynamic data.

The proposed section 4.4.4. does not exclude generation that meets the BES Exclusion criteria.  All generator in the commercial and network model (BES and non-BES) are then required to provide model data to be compliant with MOD-032.

Page 20 Section 4.4 paragraph #2 excludes generation that meets the BES Exclusion criteria from providing model data.

Page 38 Section 5.4.2.1 also excludes generators that meet the BES Exclusion Criteria.  

Either Section 4.4.4 should exclude these generators, or the exclusion removed from the above 2 sections.

PRC-006 requires generators that meet the BES inclusion criteria to provide data for the UFLS studies.   PRC-006 does not preclude using data from generators that meet the exclusion criteria,   If the new section 4.4.4 intent is to get data from non-BES generators for studies, then page 41 section 5.4.2.5 should be amended to align with section 4.4.4.

Section 4.4.2.1:

Please provide definitions for the PSSE abbreviations JDE, VM, and VA.

Sections 4.4.4.2 and 4.4.4.3:

Please define "NP". It is defined in a paragraph in section 4.4.5.4, but it would be useful to define it here where it is first introduced and most likely to be seen.

Section 4.4.4:

It is not reasonable to require that all resources in the Commercial and Network models be explicitly represented in the power flow models.  In Entergy, many of these units are behind-the-meter generation owned by industrial customers who have no obligation or desire to submit data for MOD-032. Some units are so old that the customers do not have the data necessary to accurately model them in steady state or dynamics.  Entergy has requested such data from some of these customers in the past and was told that it is not available.

1.

Section: 1. Introduction

Subsection: 1.3 Responsible Entities

Proposed in redline:

“Resource Planners (RP) are responsible for submitting modeling data for future

generating facilities with a signed interconnection agree”

Comment:

No concerns with written definition as-is, but is subject to whether the comments and recommendations provided below are considered.

2.

Section: 2. Data Submission Requirements

Subsection: 2.3 Resource Planner

Proposed in redline:

“The TO or LBA designated as Resource Planner (RP) for the area in which future planned resource(s) are being constructed shall assume the responsibility of providing necessary data for that resource(s) to MISO. The standards and data requirements should follow what is outlined and described in section 2.2 under “Generator Owner”.”

Comment:

Consider removing TO from assuming responsibilities under “Resource Planner”, and clarify that BA is not considered part of LBA. LBA in this situation should only consider the distribution side (LSE or DP). From a TO level on DERs, it is difficult to identify or track the data when resources are connected within the distribution system. Visibility into what is there isn’t readily available, and acquiring contacts should the resources be identified may prove difficult since the resource owners have no direct contact with the TO in most cases, this is done on a DP (LSE) level. MISO or the DP would have more visibility into the data and would be more accurate.

In addition to the above, it should be clarified somewhere within the document that TOs are not responsible for providing any data concerning future generating facilities with a signed interconnection agreement (including initial modeling of the units) unless a delegation agreement exists.

3.

Section: 3. Model On Demand (MOD) Training & Access

Subsection: 3.3 MOD Case Build Information Order

Proposed in redline:

Inclusion of data hierarchy and visual

Comment:

In agreement with the inclusion as is.

4.

Section: 4. Power Flow Model Development

Subsection: 4.4.1.2 Expedited Project Review Project Files

Proposed in redline:

“MOD project files that are representative of items that have been identified in the expedited project review process. File names should contain the same information as company name acronym, the EPR ID, and project name as in the example below:

Example: ITC-EPR_PRJID-PROJECT_NAME_prj”

Comment:

In agreement with the inclusion as is.

5.

Section: 4. Power Flow Model Development

Subsection: 4.4.4 Modeling of Generators

Proposed in redline:

“Any generating resource that is currently represented in the MISO Commercial and/or Network Model in the form of a GEN/ESR node is required to submit the necessary data to have that resource explicitly represented in power flow models. The various criteria for each generating resource that should be provided can be found below.”

Comment:

In agreement with the inclusion as is.

6.

Section: 4. Power Flow Model Development

Subsection: 4.4.6.2 Load Forecast Expectations

Proposed in redline:

“Submitted forecasts for load profiles should show some level of consistency from year-to-year, with the general expectation that there are no major spikes other than what would be seen through natural load growth or decline. MISO will perform some checks for each submitted load profile:

1. Comparison of current year load value to previous year load value for variances greater than 10%

2. Comparison of current year load value as a percent of previous year Module E value for YoY variances greater than 10%

3. Comparison of current year load value as a percent of previous year real-time peak load value for YoY variances greater than 10%

Any variances outside the bounds observed in the checks listed above (for example a large industrial load comes online) will be flagged by the MISO Planning Modeling team for requiring justification.”

Comment:

Consider providing examples or comment on acceptable justifications such as:

“Moving from netted DER with load to separately modeling DER.”

Maybe even consider not penalizing for net load spiking, but instead net flow spiking. As entities start modeling DERs separately and pulling them out of the load, there may be an influx of these situations so an “out” could possibly be provided within the document.

7.

Section: 5. Dynamics Model Development

Subsection: 5.6 Distributed Energy Resources

Proposed in redline:

“Dynamics data should be provided for any DERs that are represented in the power flow models. The representation that is provided can either be a generic model or a user-defined model, depending on the resource and complexity of modeling the DER.”

Comment:

Consider providing additional guidance on how to do so. A suggestion could be: modeling anything 5MW or greater with an actual model from the manufacturer to start, and increase if needed. An additional suggestion may be to aggregate by type and substation for anything smaller, and use a generic model. This would apply to both Steady-State and Dynamics modeling.

DTE would like to thank MISO for the opportunity to provide comments. DTE strongly encourages MISO to establish a threshold at which specific dynamic data should be required. Perhaps 5 MW or greater could be the threshold. Anything smaller perhaps MISO can just assign a generic model that it finds suitable. Another concern is legacy installations; for those, the utility would need to collect the information up to including site visits to verify configuration, settings and nameplates. There is likely substantial cost to do this task. 

Best,

Raluca Lascu

DTE would like to offer some additional feedback:

Table 4-3 indicates that “conceptual” projects are not included in generator base models. What is the definition of conceptual project? Alos when should a project be included? Is it after PGIA, or do you have to have an executed GIA? What about if the project is approved for testing but not technically COD?

Section 4.4.5 does not provide a threshold for what size DER are to be included. Could there be a threshold established?

What happens if the OEM for some of these DER are no longer in business?  Can we get an exemption from providing that data?  Do we only offer the minimum if we know it?  Do we have to work with the owner of the DER to try to obtain the required information if we do not currently have it?

 Step 4.4.5.3 is there a certain threshold that MISO would prefer to see an aggregated machine versus a distinct resource? 

Step 4.4.5.3 sub-bullet 2, sub-bullet 3 says “no more than one DER should exist at a single bus”, doesn’t this go against the option to provide aggregate or a distinct resource on one bus?

Section 5.4, 2^nd paragraph, notes that “on an annual basis each data owner is required to submit dynamic models to represent approved future active elements such as generators…”, when does a future element become “approved”?

Section 5.6 notes that DER can use a generic model or a UDM, but does not note that if a UDM is utilized then a TSAT model is also required or at least reference Section 6 for specifics needed when using a UDM.

Attachment 1 does not address DER model information required.

Thanks for your support,

Raluca Lascu

4.4.4.1 Synchonous Generators

MOD Project Name shall include the MISO interconnection queue study number for any generation improvements including installation or uprate • Generator Bus name shall include MISO interconnection queue designation o For example, “JXXXX Gen” (bus name limited to 12 characters)

Retaining the J### for in-service generation facilities is causing wasted time and miscommunication. Please change or clarify the requirements of this section so that the naming convention only applies to future generation projects that are presently in the MISO study queue. Once the generator is in service, it will be greatly helpful coordinating with operations, planning, commercial model submitters to use the facility name.