During the November 29, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO reviewed proposed tariff language changes to Modules A & D, Attachments X, TT & UU and Schedules 20, 29 & 29A. Stakeholder feedback is requested on the proposed language.
Please provide feedback by December 13.
Advanced Energy Management Alliance
MISO Distributed Energy Resource Task Force (DERTF)
“FERC Order 2222 – Tariff Language Module A (2021129)”
December 13, 2021
Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the feedback request made by MISO at the November 29, 2021, meeting of the DERTF.[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 November 29th meeting of the DERTF, MISO presented a limited set of potential edits for an assortment of Tariff sections.
Regarding the recommended changes suggested, AEMA is concerned with the changes presented for Module A, related to the Definition of a DEAR (Distributed Energy Aggregated Resource). In the redline proposal, MISO has introduced a maximum size for the DEAR of 10 MW. The maximum size limitation should be removed.
In the meeting on November 29, MISO stated that the rationale for this limit was driven by two factors. The first factor was the IMM recommendation to not conduct mitigation on resources that have less than 10 MWs injection capability and the second factor was the proposal for MISO to “auto approve” outages on resources less than 10 MWs in size. Neither of these rationales are reasons to impose a broad sweeping limitation on the maximum size. The recommendations related to Market Monitoring and Operational Coordination highlight an important recognition that smaller DEARs have little impact on overall system operations and that the effort involved in imposing tight monitoring on these smaller resources is not justified. Creating the 10 MW threshold for some of these operational aspects eliminates barriers to participation for small DEARs. AEMA supports the Market Monitoring and Operational Coordination recommendations to exclude resources below 10 MW from requirements; however, MISO should allow larger aggregations to participate in the market, subject to broader operational coordination requirements and monitoring.
Another issue raised in the November 29th meeting of the DERTF was concerns expressed by stakeholders that a DERA could potentially escape market mitigation exposures by breaking a single DEAR that was more than 10 MWs into multiple small resources, each below 10 MW in size. The proposal by MISO to limit resources to less than 10 MW in size would force a market participant to do exactly what was raised as a concern from stakeholders and the IMM by requiring them to create multiple DEARs at a single location where more than 10 MWs of aggregated resources exist.
For these reasons, MISO should eliminate the 10 MW maximum size limit for DEARs.
AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed at the DERTF. 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 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
Please see attached. Thank you.
TO: MISO DISTRIBUTED ENERGY RESOURCE TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FERC ORDER 2222 FILING FRAMEWORK – TARIFF REDLINES
DATE: DECEMBER 13, 2021
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the November 29, 2021 Distributed Energy Resource Task Force (DERTF) meeting concerning the FERC Order 2222 filing framework and the related topic of Tariff redlines.
Tariff edits to Modules A & D, Attachments X, TT & UU as well as Schedules 20, 29 & 29A
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
In the cases of the following proposed tariff changes for compliance with O2x4, WPPI provides feedback in the corresponding redlines doc (attached):
WPPI does not have any edits to propose to the following sections:
Voltus Comments to MISO regarding Tariff edits to Module A
MISO defines DEAR as “Distributed Energy Aggregated Resource: an aggregation of individual Distributed Energy Resources which are registered as a single resource for participation in the energy, ancillary services, or capacity markets. An aggregation may not have a capacity smaller than 100kW, and may consist of a single asset. The maximum size for a distributed energy aggregated resource is 10MW.”
Voltus recommends striking the 10 MW size maximum size limitation because, in our experience, there are single-site facilities on their own that are 10 MW and higher. Hence limiting the maximum size for a DEAR at 10 MW would not just force aggregators to reshuffle aggregations-- it would bar some individual DERs from market participation.
Additionally, this 10 MW size limit has not been discussed at the Interconnection Process Working Group (IPWG). MISO should note that there exist limitations on the distribution system due to the hosting capacity of the distribution feeders. Each distribution utility conducts its interconnection analysis based on the results of hosting capacity analysis. Setting up a 10 MW size limitation further restricts what the MISO DUs can study in their DG/DER interconnection requests.
Voltus proposed redline is, “DEAR: Distributed Energy Aggregated Resource: an aggregation of individual Distributed Energy Resources which are registered as a single resource for participation in the energy, ancillary services, or capacity markets. An aggregation may not have a capacity smaller than 100kW, and may consist of a single asset. The maximum size for a distributed energy aggregated resource is 10MW.”
Advanced Energy Management Alliance
MISO Distributed Energy Resource Task Force (DERTF)
“FERC Order 2222 – Tariff Language Module A (2021129)”
December 13, 2021
Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the feedback request made by MISO at the November 29, 2021, meeting of the DERTF.[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 November 29th meeting of the DERTF, MISO presented a limited set of potential edits for an assortment of Tariff sections.
Regarding the recommended changes suggested, AEMA is concerned with the changes presented for Module A, related to the Definition of a DEAR (Distributed Energy Aggregated Resource). In the redline proposal, MISO has introduced a maximum size for the DEAR of 10 MW. The maximum size limitation should be removed.
In the meeting on November 29, MISO stated that the rationale for this limit was driven by two factors. The first factor was the IMM recommendation to not conduct mitigation on resources that have less than 10 MWs injection capability and the second factor was the proposal for MISO to “auto approve” outages on resources less than 10 MWs in size. Neither of these rationales are reasons to impose a broad sweeping limitation on the maximum size. The recommendations related to Market Monitoring and Operational Coordination highlight an important recognition that smaller DEARs have little impact on overall system operations and that the effort involved in imposing tight monitoring on these smaller resources is not justified. Creating the 10 MW threshold for some of these operational aspects eliminates barriers to participation for small DEARs. AEMA supports the Market Monitoring and Operational Coordination recommendations to exclude resources below 10 MW from requirements; however, MISO should allow larger aggregations to participate in the market, subject to broader operational coordination requirements and monitoring.
Another issue raised in the November 29th meeting of the DERTF was concerns expressed by stakeholders that a DERA could potentially escape market mitigation exposures by breaking a single DEAR that was more than 10 MWs into multiple small resources, each below 10 MW in size. The proposal by MISO to limit resources to less than 10 MW in size would force a market participant to do exactly what was raised as a concern from stakeholders and the IMM by requiring them to create multiple DEARs at a single location where more than 10 MWs of aggregated resources exist.
For these reasons, MISO should eliminate the 10 MW maximum size limit for DEARs.
AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed at the DERTF. 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 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
The Environmental Sector recommends that MISO strike the proposed Module A setting a 10 MW maximum size limit for Distributed Energy Aggregated Resources (DEAR).
The Environmental Sector requests that MISO discuss proposed changes to Attachment TT and Schedules 29 & 29A at a future DERTF meeting.
The Environmental Sector agrees that DEARs can include energy efficiency resources as part of the aggregation.