DERTF: Discussion Topics for EDC Workshops (MSC-2019-2) (20240111)

The Entergy Operating Companies submit the following feedback for consideration in the January 22, 2024 EDC Workshop, focused on Reliability Reviews, as requested by MISO in the January 11, 2024, meeting of the Distributed Energy Resources Task Force (DERTF).

General comment applicable to all of the January 11 DERTF feedback requests:  Dispatch information is needed by multiple parties throughout the process, for the technical review, operational reliability, and ultimate performance validation and settlements.  The same data protection concerns would exist as those that are relevant to the MDMA question.  A common, access-protected, database should be considered. 

The limited timing requirement (60 days) needs to be considered in the context of other Order 2222 Compliance elements that impact the timing considerations of EDC Reliability Review:

• Location of assets permitted in the aggregation
  • The more complex the aggregation, the more complex the associated EDC review.  To accomplish a 60-day review period, any change in the composition of an Aggregation will require a new Review.
• Timing considerations:
  • EDC GI and MISO Affected System studies relative to registration in an aggregation
    • MISO is envisioning the GIP to be “separate and parallel”
      • If the Interconnection Study has not been completed for a DER included in an Aggregation, it will be difficult for the EDC to assess the impacts of the Aggregation
  • LMRs can only register once a year; DRRs/DER can register quarterly (coincident with Commercial Model updates).
    • Under this construct it should be anticipated that there will be more registrations to evaluate at the time when LMRs can register.
    • The EDC Review schedule should be coordinated with the Asset Registration schedules and should provide additional lead time for annual LMR registrations.   
  • The EDC will need to know the Market Services the Aggregator wishes to offer when the Reliability Review is performed.
    • If the Aggregator seeks to provide Services not studied in the initial Reliability Review, a new review would likely be required.

Alliant Energy provides the following suggested topics for discussion at the EDC Workshops:  continued discussion on how EDCs plan to approach reliability reviews, what will encompass the eligibility review and discussion of times and coordination with retail interconnection processes.