During the June 21, 2023, Planning Subcommittee (PSC) meeting, MISO proposed several principles to advance DER data exchange. MISO is requesting Stakeholder feedback on MISO proposed approach, with particular focus on the following:
Please provide feedback by July 17.
The OMS Distributed Energy Resources and Transmission Planning Work Groups (OMS DER & TP Work Groups) appreciate MISO’s work on DER modeling and data exchange and appreciate this opportunity to provide feedback. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.
The OMS DER & TP Work Groups offer the following feedback:
1.) The OMS DER & TP Work Groups appreciate MISO raising these DER modeling and data exchange issues to the Planning Subcommittee. However, we request that MISO also introduce these issues at a future DER Task Force (DERTF) meeting so that distribution experts can offer their perspectives. As stated elsewhere, these experts do not typically attend MISO meetings outside the DERTF. If MISO wishes to work with distribution level personnel on these or other items, it would be best to present this material at the DERTF to ensure they are informed of MISO’s intentions, which could impact their day-to-day work.
However, this feedback request closes on July 17 before the next DERTF is scheduled for July 27. As such, the OMS DER & TP Work Groups recommend that MISO provide an informational update on these issues at the DERTF and direct stakeholder attention to this PSC feedback request to avoid overlap. In the future, if MISO intends to continue to raise DER issues in forums other than the DERTF, it may be best for MISO to coordinate updates with the DERTF leadership and management plan to ensure distribution experts are able to participate in a timely manner.
2.) The OMS DER & TP Work Groups encourage MISO to consider whether the CUS DER Registry presented at the April DERTF is an appropriate and useful tool for solving this and other information and data sharing problems associated with DERs and Order No. 2222 compliance.
3.) The OMS DER & TP Work Groups encourage MISO to continue to coordinate with distribution-level entities and state regulators to access the data it needs. The Work Groups acknowledge the need to improve DER modeling, particularly as DER penetration increases, and it is evident that distribution-level utilities are best positioned to provide the necessary information to MISO. This is especially true of the granular level of information that MISO is seeking here.
To the extent that steady state and dynamic data is unavailable for every individual DER or excessive for MISO modeling purposes, it may be useful to think through how such data may be aggregated at the distribution/transmission interface.
MISO will need to rely on distribution utilities to aggregate the information they have collected through DER interconnections and other processes and make that information digestible and useful for MISO modeling purposes.
Transmission Owners Feedback to PSC on Proposed Principles to Advance DER Data Exchange
https://cdn.misoenergy.org/20230621%20PSC%20Item%2005%20DER%20Modeling%20Update629334.pdf
July 17, 2023
During the June 21, 2023, Planning Subcommittee (PSC) meeting, MISO proposed several principles to advance DER data exchange. MISO requested Stakeholder feedback on their proposed approach, asking stakeholders to focus on:
The MISO Transmission Owners appreciate MISO taking a comprehensive approach to this effort, given the number of entities being newly subjected to transmission planning data exchange requirements and the volume of new data that is going to be required to be gathered and exchanged. Increasing overall communication by all parties, standardizing both the forms and processes and gaining a clear understanding of the information to be exchanged will enable this new approach to be the most effective. The kind of thoughtful approach outlined by MISO is also particularly important due to the evolution of industry standards underway, as noted in MISO’s presentation to the PSC in June.
In addition to the comments on MISO’s general principals and framework below, the Owners reiterate our request, following the April PAC meeting[1] on the DER AFS process, that the details necessary to implement that process, outlined in our feedback, be discussed in the PSC as we approach October implementation. MISO’s DER Data Exchange workplan should be included in the DER AFS process, as the information exchange will be necessary to implement this new process as discussed in MISO’s presentation on this topic at the June PSC. A comprehensive understanding of the penetration of DER is necessary to really gain an understanding of its effect on the BES not only today but also as DER penetration increases in the future. As described in more detail below, the need for increased visibility, driven by increased penetration, in turn increases the need for engagement and coordination and all impacted parties, specifically Distribution Providers and their Retail Regulators.
MISO’s general principles for viewing DER data exchange refinements:
The transmission owners appreciate MISOs identification of general principles for data exchange refinements, and the opportunity to provide feedback on these principles:
The Owners agree that it is appropriate to avoid having DER recorded both as a negative load and as a generator, but the phrase “avoid double counting” is typically used to refer to a retail-sited resource providing the same service to more than one party at the same time and being paid for that service more than once. (In a planning case, the way MISO is using the term is correct). It would be helpful going forward to revise the wording of this particular principle to better reflect the reference to how the resources are being modeled, such as, “Aim to avoid model misrepresentation.” The key principle that needs to be reflected is that entities will need to confirm that generation is not being included in a net load and also as part of a generation aggregation. To be clear, many DERs are not individually metered as they are connected behind the retail meter (e.g., net metered installations). Simply knowing that these net metered DERs exist and explicitly modeling them based on their nameplate as identified in a data exchange database will most likely result in erroneously modeling the impact of the DER up to twice the installed capacity. Therefore, explicit modeling of DER should be limited to DER that has a stand alone meter whereby utilities are able to appropriately determine the gross load and avoid erroneous modeling.
The Owners agree that this is an important and necessary principle, specifically with regard to the concerns described in the responses to the other principles and overall framework MISO has set forth in the June 21st PSC presentation.
Per the details provided in the comments above, it is important that requirements for alignment reflect the availability of data rather than mandating full alignment as the starting point. Many TOs and other entities may need to work with Distribution Providers to set up processes to obtain the needed data and models.
Targeting the cumulative effects of DERs in all transmission system reliability studies will be increasingly important as DER penetration grows. The incorporation of DER into the MISO planning models should be completed on an as installed basis throughout the MISO footprint accurately representing only that DER that has been connected. This will allow the transfer of known DER information to the Operations model.
Consideration of individual DER threshold sizes is appropriate and necessary, as discussed in the other responses to the Principles and Framework. This is a key factor in the phased approach proposed by MISO. Ramping up these size thresholds, i.e. starting with large DER as MISO has suggested, is not only appropriate, but also necessary from both the perspectives of data availability and relevance to BES Reliability Planning.
Suggested improvements to the general approach
The TOs support MISO’s proposed phased approach to incorporating DER data exchange requirements into the Transmission Planning process to support and gain visibility into potential DER impacts on the BES. Recognizing that DER data exchange is subject to the engagement of entities who are not necessarily familiar with Transmission System Planning requirements, the Owners again stress the need for MISO to
As noted in the comments above, given that DER data exchange requirements are a new frontier in transmission system planning, it is likely that many of those impacted by these evolving requirements are not currently participating in MISO’s planning forums, and targeted outreach will be necessary to ensure their necessary engagement. To ensure that retail regulators and Distribution Providers, in addition to transmission planners and policy makers are involved in these discussions, the Owners recommend that MISO reach out through the following stakeholder forums:
MISO’s proposed data exchange process should include the development of a standard form for data information exchange, to capture the information needed for modeling, including:
Generally, the pace at which data exchange requirements relating to the assessment of the potential impact of DERs on the BES can advance must consider:
Finally, the workplan for incorporating DER data modeling into transmission planning also needs to maintain awareness of and alignment with evolving IBR requirements as they are being developed both within the industry and implemented by MISO. Some of this work is anticipated to occur through the IPWG or is currently underway there. A thoughtful and coordinated plan will be needed to achieve the alignment of these two objectives.
MISO PLANNING SUBCOMMITTEE - DER MODELING UPDATE
COMMENTS OF COLLABORATIVE UTILITY SOLUTIONS
Collaborative Utility Solutions (“CUS”) thanks MISO for the opportunity to provide comments on its approach for advancing DER modeling data exchanges. CUS is a non-profit entity formed to address key needs common to the electric industry in a manner that will save the entire industry significant costs while rapidly advancing the enablement of distributed energy resources (DERs) for grid and market purposes. CUS’s goal is to develop and support those industry processes and systems that can be collaborative and shared from utility to utility or market to market and, therefore, implemented at a dramatically reduced cost to create a much more efficient shared ecosystem of use by all the stakeholders in the energy value chain. CUS’s objective is to partner with electric industry stakeholders and find the opportunities to collaborate and provide effective tools that can be used by everyone. Our initial focus is to provide a pre-competitive collaborative DER Registry for the industry to enable DERs to more efficiently and effectively support and interact with the grid and markets.
Overview of DER Data “Needs and Uses”
Over the past 5 years, CUS team members have worked around the world, particularly in Australia, on DER implementations in markets and DER data sharing/exchange approaches. CUS applauds MISO’s initiative being undertaken early in the process instead of as an afterthought like happened in Australia and many other jurisdictions around the world.
The administrative process to register a DER, allow it to be aggregated into a group of DERs (DERA), and then be presented to participate in a retail program or market has proven to be a costly and difficult exercise. Why? Because DERs are not ‘business as usual’.
FERC Order 2222 is not setting up a wholesale market for a few tens of thousands of bulk generators that are owned by a few hundred entities like FERC Order 888/889. It is establishing a market for millions of generators owned by millions of different people, the vast majority of which are not educated about or focused on the intricacies of the wholesale electricity market. With FERC Order 888/889, the electric industry was able to use brute force on many practices and make it work because there were very few systems, entities, and processes affected. Spreadsheets, email, and manual processes were clunky, but they worked because the volumes were not overwhelming and cyber threats were just coming of age. In contrast, DER volumes will be overwhelming, almost every utility system will be affected (CIS/GIS/ADMS/DERMS/EMS/etc.), and cyber security is paramount. DER data will constantly change versus a largely static data set for the large scale generators. And finally, it is important to recognize the increased number of different stakeholders that will require access to DER Data. This reality requires the industry to look beyond their specific, or siloed, issues and collaborate broadly to address this fundamental change that DERs and Order 2222 represents for our industry.
In MISO’s presentation, “DER Modeling Update”, June 21, 2023, at page 7, MISO sets forth several principles for advancing DER data exchange, with the first being “Take a reliability-focused approach”. CUS agrees that MISO’s primary focus is the reliability of the bulk power system, and that issue always should remain the focus for MISO. However, CUS encourages MISO and its stakeholders to consider the entire DER picture and avoid pursuing a siloed view of DER data that does not include all the processes and stakeholders that will require access to DER data. A data-centric approach that is compatible with Common Information Model (CIM) principles will ensure the most effective and efficient implementation for DER data collection and sharing that will support grid reliability.
Approximately 30 years ago, the electric industry began utilizing software-based Energy Management Systems (EMS). The industry was struggling with custom interfaces to every generator/turbine manufacturer. EPRI took up this challenge and determined that the electric industry needed a Common Information Model (CIM) that all generators must comply with to ease implementation and operational coordination of the generators with the electric industry’s new systems. CIM was developed as an open standard for representing power system components and has been adopted by the major EMS vendors. Over the past 30 years, the CIM initiative was moved to the International Electrotechnical Commission (IEC) and has grown to serve generation, transmission, distribution, retail, and market structures, etc. As Yogi Berra said, "It's like déjà vu all over again." Here we are 30 years later solving the exact same problem of a CIM for generators, but this time it is for millions of facilities rather than a few thousand.
In addition to a Common Information Model, it is critical to incorporate a comprehensive and holistic data collection and secure sharing strategy. The following diagram illustrates this need:
Starting at the top of the chart, DER data is created for the first time in the permitting process. Proceeding clockwise, a portion of this data is then needed in the interconnection process. Utilities and ISOs use the submitted data for planning and modeling in their systems to approve or reject the interconnection request. If approved, Geographic Information Systems (GIS) systems need the DER data to show where these resources are both geographically and electrically on their system. Once a utility or the Independent System Operator (ISO) establishes a DER program or market, an aggregator (utility or competitive entity) needs the data to create their aggregations and submit them for review and approval to a retail program or market. At this point, each retail program or market will have established rules for the appropriate stakeholders to review and approve the aggregation. This process will include the DER owner, aggregator, DSO, competitive retail supplier, scheduling coordinator, TSO, and ISO, all with appropriate regulatory oversight. All of these stakeholders will need access to appropriate portions of the DER data. Customers that agree to participate in a retail program or market will need to assign the DER to an aggregator to allow an aggregator to create aggregations and then allow all appropriate stakeholders to review and approve the aggregation. Once approved, the EMS operational and market systems will require access to DER and DERA data. Utilities will need to be able to present planned and unplanned outages on their system via a ‘distribution oasis’ like currently exists for transmission as the distribution system will now have market resources embedded within it. And along the way, people will move in and out of houses with DERs installed on them, people will add batteries to their solar arrays, people will add and sell (delete) EVs, people will want to change aggregators or programs, grid operators will reconfigure their networks or market zones/nodes/regions, aggregators will go out of business, utilities will change names, etc. Operational systems will need to verify performance. Settlement systems will need access to the DER data for billing/payment. And, finally, regulatory and government agencies will require reporting on all of this. Attempting to consider any aspect of this process in isolation has proven very problematic.
If a data centric approach is utilized to define the necessary data elements for each step in this process and these data elements are appropriately ‘mapped’ to CIM data structures, then existing industry systems for CIS, GIS, ADMS, EMS, planning and modeling, etc. will be able to effectively share the data through a secure data API based on the CIM data structures of the existing industry systems, thereby eliminating software interfaces. This approach is designed to allow DER data to conform to existing systems in the electric industry rather than modifying dozens, or even hundreds, of industry systems to utilize DER data. With this thought process in mind, CUS has interacted with many different stakeholders over the past few years to address these defined needs by building a non-profit collaborative DER Registry platform. The DER Registry is intended to facilitate a collaborative approach to sharing DER data as well as a collaborative approach to the continued development of the DER Registry itself.
CUS Collaborative Non-Profit DER Registry
The DER Registry is a pre-competitive tool that can be implemented by each ISO and each state and their utilities but done collaboratively with shared costs. This creates a registry that is designed and built once (no multiple overlapping systems) and then constantly improved with all stakeholders’ input for the benefit of all. This approach is expected to cost less than one half of one percent of the cost of “business-as-usual" to implement multiple proprietary registries for the entire country. With a collaborative system, all existing utility and ISO systems can now have a standard, CIM-based interface to the DER Registry that does not require software integration. Instead, data exchange is securely enabled through the CIM ‘plug-n-play’ standard the electric industry already utilizes. This will allow all ISOs, utilities, customers, aggregators, their regulatory authorities, and other industry stakeholders to share a common view and understanding of the DER resources of concern to them. At the same time, the DER Registry is designed to allow regulators to specifically identify which stakeholders have access to which pieces of data, allowing detailed customization of data access to reflect unique local needs. And the annual costs to continually improve and maintain the system will be less than one percent of the costs of a multitude of disparate proprietary systems.
Implementing this collaborative DER Registry will rapidly enable consumer DERs and competitive DERA offerings and speed the effective integration of DERs/DERAs into the electric grid and market systems for the industry, regardless of market structure. It will enable utilities and new players to create applications to utilize and optimize DERs instead of putting time and money into simply gaining access to the base data. It also will support effective interconnection processes and many other supporting activities across the industry, reducing those costs too. It will eliminate a decade of confusion and consternation between consumers, utilities, markets, and competitive DER suppliers, ISOs, and regulators while providing the foundation to ensure we can move more quickly towards a clean energy economy. With this structure in place, DERs can begin to be used to solve problems instead of creating them, and the cost burden to consumers in the US will be far less than the cost of doing it through ‘business as usual.’
The DER Registry recognizes there will be a variety of ways that data will be brought into the Registry. It has been structured to facilitate these processes and has a dynamic approval engine that is easily adapted to any utility or ISO approval structure. In addition, CUS is currently working with leading industry platforms for DER permitting and interconnection on the possibility of APIs to further simplify enablement of DERs.
As noted above, the DER Registry also is designed to recognize that different regulatory authorities may have different views on who should be allowed to access the different data elements in the Registry. Therefore, the DER Registry has been designed to allow each regulatory authority to specify which stakeholder can access any individual data element in the Registry. Per the graphic below, the regulatory authority can specify, for every data element in the Registry, who should be allowed to view that piece of data. CUS understands that each state or ISO’s legal governance of an aggregator participating in a market program may be an unresolved issue. However, we also believe that aggregators would voluntarily support these data privacy rules if required to allow them to expand their portfolios. The DER Registry makes any required privacy rule or process much simpler for everyone to adopt by securely managing and sharing only necessary data with each appropriate stakeholder.
As the graphic below shows, this structure allows the Registry to securely provide the necessary information to stakeholders and effectively facilitate the entire administrative process to register a DER, create a DERA, effectively bring it to market, automatically provide any required reporting, and effectively manage any changes along the way.
Collaborative Utility Solutions Structure
CUS was formed to support the industry by providing a DER Registry at the lowest cost possible through a non-profit company that the industry will control and guide as the industry evolves and begins making DERs valued resources for grid reliability and retail programs and the market. CUS’s Board of Directors has been designed to allow a voice from each stakeholder industry group on the Board, and a member user group is in control of changes/improvements to the Registry with approval from the Board. And unlike a traditional competitive software vendor, these changes are included in membership fees and are not incremental charges. This structure allows the Registry to become less expensive over time instead of more expensive as CUS has more members utilizing the Registry. This structure also allows all stakeholders in the industry to be represented and provide a leadership role in continual improvements to the Registry over time.
As a non-profit entity, CUS exists solely for the purpose of supporting our members to bring common solutions like the DER Registry to the electric industry. Electricity is the lifeblood of the world we live in, and CUS seeks to lower the cost of deployment and on-going support of broad industry solutions while improving the effectiveness of the entire energy value chain for all stakeholders. As CUS grows and our membership increases, the cost of providing solutions will continually decrease. The CUS Board of Directors will review and adjust all membership fees annually to cover only CUS’s budgeted costs for the following year – a budget driven by CUS’s members. Again, as a non-profit designed specifically to serve the industry without a profit motive, CUS has the unique ability to leverage the tools CUS creates in partnership with its members at a continually decreasing cost. CUS also has designed the membership fees in a manner to eliminate “pancaking” of expenses. For example, MISO, as an ISO, and state utility commissions in MISO that have utilities that participate in the DER Registry will not pay membership fees to CUS. This structure recognizes that a fee assessed to MISO and the state commissions would be passed on to utilities and other stakeholders who will pay membership fees themselves – a pancaking that can add needless administrative expenses. For more information regarding CUS’s membership fees, please see www.cusln.org/membership. All financial information will be publicly available as required by the IRS for our non-profit status.
Conclusion
DERs are a fundamental change in the way the entire electric industry will work in the future. Our planning will no longer be top down. We will begin to plan bottom up and optimize our entire grid one feeder at a time with targeted deployment and distributed control of DERs. The industry will be able to recognize the solutions and efficiencies DERs can bring to the industry, such as correcting power factor and phase balance on each feeder and reducing technical losses by as much as 50%. DERs’ contribution to capacity and energy, combined with these efficiency gains, can provide much needed capacity for electrification initiatives like EVs while also supporting energy storage and balancing for bulk renewables. DERs are a solution to hundred-year-old problems on our grid and can provide incredible flexibility to markets. However, if we do not solve the administrative issues of even being able to register them, our brilliant engineers will never have access to fully utilize them for any of these purposes.
The electric industry has spent the last two decades fragmenting itself into isolated silos of generation, transmission, and distribution across a variety of market structures. This has caused the industry to continually create more systems for specific, isolated issues. DERs cross all technical and structural boundaries and are a crucial element for the future of our grid’s reliability, a stable and affordable price of electricity, and support of a clean energy economy. The only way the industry will achieve these goals is to set aside the industry’s individualistic views/needs, recognize the larger DER picture, and collaborate effectively to enable DERs.
In an era of ever escalating IT costs, CUS is excited to bring this new model to the industry for secure, collaborative, shared systems, and tools. CUS looks forward to working with all stakeholders in the electric energy value chain to find and leverage common interests for the benefit of all.
Respectfully submitted,
__________________________________
Chris Hickman
Chief Executive Officer
Collaborative Utility Solutions
8404 Lakewood Ridge Cove
Austin, TX 78738
Telephone: (970) 237-0990
Feedback by Public Service Commission of Wisconsin (PSCW) Office of Regional Markets (ORM) Staff to MISO on DER modeling data exchanges
As MISO develops a path forward on this topic, we hope that MISO will offer stakeholders more information about the following as soon as possible:
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. 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. Perhaps there could be an exemption for legacy systems where all this data may not be required.
Best,
Raluca Lascu P.E.