In the September 27 meeting of the Planning Subcommittee, MISO discussed DER modeling items as they pertain to the pending MOD-032-2 revision. As a part of this conversation, MISO is requesting feedback on challenges that stakeholders anticipate having in getting DER information submitted to MISO.
Feedback due date extended to November 15.
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 and or steady state data should be required even with the phased in approach. Perhaps 550 kW 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. Perhaps there could be an exemption for legacy systems where all this data may not be required. DTE would also welcome some guidance from MISO on how to calculate some of the parameters for aggregate installations where the POI's are at distribution voltage level, but at different EP nodes. How should the models reflect temporary changes of the POI due to load transfers both at the substation and on the overhead circuits? Thanks for the support, Raluca Lascu
Since MISO wants to base its MTEP models on coincident load forecasts, MISO should specify a date and time on which each model should be based, e. g. July 15th at 1600 EDT for Summer Peak. In that way, data submitters can adjust both their own load forecasts and DER solar outputs accordingly. This will be helpful in all MTEP models, but especially in summer shoulder models where the date and time of the summer shoulder was not defined relative to the summer peak.
Transmission Owners Feedback on MISO’s proposed approach for advancing DER modeling in planning reliability models
November 15, 2023
The MISO Transmission Owners (TOs) submit the following feedback in response to MISO’s presentation at the September 27, 2023 Planning Subcommittee meeting, regarding DER modeling relative to the pending MOD-032-2 revision, and to MISO’s request for feedback on challenges stakeholders anticipate having in getting DER information submitted to MISO.
The Owners recognize that the lack of DER modeling will become more impactful to BES reliability as these resources increase in penetration installation across the footprint, and without accurate modelling for these resources, other generation assets will likely have to respond in ways not yet contemplated by modeling.
In response to feedback requested by MISO:
MISO’s draft framework for timing and thresholds of recommendations for DER inclusion in the MISO Series models.
MISO has proposed thresholds for the inclusion of DER modeling data in MISOs MTEP models. For existing generation, a size-based approach makes sense, but may create re-work if records review is needed to get the initial data set. However, these thresholds should not apply to newly interconnecting DER; the information should be collected when the DER interconnects, and new DER should all be modeled.
Generally, the timeline appears to be achievable, but as described in more detail below, there are many complexities that must be resolved in the interim in order to realize this goal. Additionally, Owners would have concerns with the liability associated with submission of data that they do not own. For perspective, Owners do not submit generator data to MISO for facilities that they do not own.
Challenges with access to and submission of required modeling data for DERs
Owners Feedback on MISO’s Guiding Principles:
Work to align visibility in both the Planning and Operations Models:
Align with current and evolving State-jurisdictional processes and utility practices:
Align DER modeling granularity with existing MISO modeling practices:
Target cumulative effects for steady state data exchange:
Consider individual threshold sizes (i.e., large DER) for dynamics data initially:
American Municipal Power (AMP) appreciates the opportunity to provide feedback on MISO DER Modeling and offers the following comments.
Consumers Energy would like MISO to consider using a hybrid approach of discretely modeling larger DER generators while aggregating smaller DER generators. We would propose a discrete modeling threshold of 550 KW and allow smaller DER to be aggregated to a gross nameplate value where MISO uses industry expertise to assign generic DER performance for steady state and dynamic models. Requiring TO’s or DP’s to provide dynamic models for these smaller aggregated units presents compliance issues because these DER interconnections and the information provided in the applications are regulated by RERRA’s and not the utility.
Consumers Energy requests MISO consider a grandfathering clause on certain modeling data for DER already installed. DP’s and TO’s would have nameplate data and could make assumptions of steady state modeling based on the settings required at the time of interconnection, but dynamic data may not have been captured. This would induce significant cost and take considerable time for utilities to attempt to coordinate with existing DER owners, especially if a minimum threshold is not established.
Different sizes of DER may have different settings requirements established by a utility. Creating an accurate aggregated model would prove difficult. DP’s also may not have the in-house expertise for dynamic modeling of this nature. Consumers Energy welcomes MISO’s guidance in making assumptions and the modeling parameters MISO may want to see used.
Consumers Energy is interested in how MISO intends to use/adjust the DER modeling provided. If MISO will be scaling the DER dispatch, or intends to in the future, would DP’s need to split out aggregated modeling by fuel type? Load forecasts are also closely related to DER penetration. MISO should allow DP’s to dispatch the DER as the DP’s see fit to align with company load forecasts and these values should not be changed unless similar consideration for why the DER is being adjusted is also applied to the load values. The DP’s should control the net injection/consumption modeling at each load bus.
James McCormick