In the March 11, 2024, meeting of the Distributed Energy Resources Task Force (DERTF), stakeholders were invited to review and submit feedback on FERC Order 2222 Compliance Tariff Redlines (MSC-2019-2).
Please provide feedback on MISO’s proposed Tariff redlines for Module A and Module C on the following:
Please provide feedback by April 1, 2024.
Entergy Operating Company feedback on MISO’s Order 2222 Compliance Proposed Tariff Redlines for Module A and Module C Presented at the March 11, 2024 DERTF Meeting, on:
Posted at: 20240311 DERTF Item 03a Dispute Resolution (MSC-2019-2).pdf
Are being submitted via email on March 29, 2023, due to apparent size limitations on the tool.
American Municipal Power (AMP) appreciates the opportunity to provide feedback on the FERC Order 2222 Compliance Tariff Redlines. AMP has reviewed the Tariff redlines for Module A and Module C and find that the language appropriately addresses the needed changes associated with Dispute Resolution, Reliability Reviews & Affected System Studies – Reliability Review and Eligibility Review, and Operational Coordination of DER Aggregations.
Feedback on document posted for 20240311 DERTF Item 3a
https://www.misoenergy.org/events/2024/distributed-energy-resources-task-force-dertf---march-11-2024/
As a global point for MISO’s structure of Tariff documents for Order 2222, we would point out that LBAs typically do not have visibility into the distribution systems of all the EDCs inside of their LBA. This will be true for most LBAs that are not geographically aligned with a single EDC. As the MISO implementation structure for Order 2222 evolves, we encourage MISO to work with the LBAs and EDCs to develop data flows and process charts so that we can work through data and modeling gaps, if any, early in the design and development of both systems and business process.
WPPI’s comments on the proposed Tariff redlines posted with the 3/11/2024 DERTF meeting materials (Item 03a Tariff Language – 03a 03b 03c Tariff Modules A and C_redlines) can be found under “Supplemental Stakeholder Feedback.”
Xcel Energy appreciates the opportunity to provide feedback regarding MISO’s proposed Tariff redlines from the March 11 DERTF regarding operational coordination and dispute resolution.
Operational Coordination
In Tariff Sections 38.1.1(o) and 38.1.1(z), MISO added a sentence that “[T]he LBA will coordinate and communicate such information with the EDC.” Some of this information, such as start and stop times of the DEAR should be fairly easy for the EDC to access through the MCS and/or DRT through certificate assignment of roles. However, communication of DEAR Setpoint Instructions and Dispatch Targets from the LBA to the EDCs could take extensive investment as there is no capability to share this information with EDCs today. It is our understanding that most EDCs do not have current capabilities to process this information in an expedient manner. This could be part of a distributed energy resource management system (“DERMS”) if the capabilities are developed and are affordable, but this will take time and capital. In addition, software integration would be needed to exchange data between the LBAs and EDCs, and cybersecurity requirements would need to be considered. Including this requirement in the Tariff does not allow for the flexibility and time that LBAs and EDCs need to implement technology and processes that currently do not exist.
For communication of distribution level outages or abnormal configurations, MISO should develop a system and set of processes similar to today’s “CROW” application used for transmission and generation assets. This would enable one solution instead of each EDC developing a separate solution to communicate outages and abnormal conditions. It would also be a more efficient means of handling the impact of distribution outages to the offer, versus the expectation that the DERA will have enough time to update their offers prior to the impacted RT interval. In addition, it should be noted that some EDCs do not have a manner to report distribution outages in “real-time” as this is a capability typically driven by Advanced Metering Infrastructure (AMI) and also outage management systems.
Dispute Resolution
MISO’s Tariff revisions to Section 38.7.D state:
“The Transmission Provider shall review the participation of a DERA in the Energy and Operating Reserve Markets when notified the DERA’s settlements have been successfully disputed more than ten percent (10%) of the time by a relevant LSE over a period of twelve (12) consecutive months and the financial impact(s) of such successful disputes exceeds seven thousand five hundred dollars ($7,500.00) for an individual dispute or one hundred thousand dollars ($100,000.00) in the aggregate for all successful disputes, as further set forth in the BPM for Market Settlements.”
We are concerned that the threshold limits for MISO to review the disputes are excessive based on the material effort demanded of the LSE to substantiate the settlement data provided by the DERA. We would propose setting an initial threshold of $5,000 per individual dispute or a $50,000 aggregate threshold across any time period, not just a consecutive twelve-month period. Evaluation of the thresholds should continue over time to strike a balance between accuracy and impact.
We would also recommend that all DERA settlement disputes that exceed the thresholds should always be referred to the IMM, as well as to the RERRA.
The OMS Distributed Energy Resources Work Group (DERWG) provides this feedback to MISO regarding its proposed compliance tariff redlines. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.
DEAR Dispute Resolution Process
“Disputes relating to the interconnection of a DER with an EDC, except disputes regarding the Transmission Provider’s assessment of the potential impact of such the interconnection of a DEAR, of the impact of a or an individual DER within such DEAR, on the Transmission System.”
This section should be clarified, as a DEAR does not ‘interconnect’ because a DEAR is simply the wholesale aggregation of DERs that have (previously) individually interconnected to the distribution system. The exception to this rule is if a DEAR is comprised of a single DER. A DEAR does not ‘interconnect’ to either the wholesale or retail system so the tariff language should specify that the impact of the DEAR is being studied, with the impact being the cumulative impacts from the underlying DERs, acting in a coordinated manner, under a DEAR. A suggested replacement could read, “except disputes regarding the Transmission Provider’s assessment of the potential impact of a DEAR or the interconnection of an individual DER within such DEAR, on the Transmission System.
Reliability Reviews and Affected System Studies - Reliability Review and Eligibility Review
“This ten (10) Business Day period will occur in the first ten (10) Business Days within the sixty (60) Calendar Day period specified in Section 38.7.A.iii.2.”
This language needs to be clarified. It is unclear where in the 60-day period the RERRA review is intended to occur. MISO verbally stated the RERRA review would occur on Day 11 of 60, after the EDC reliability review has been completed. If this is the intent, the language above should reflect a Day 11 start date, while the EDC concurrently conducts its reliability review. As the OMS DERWG previously submitted[1], the RERRA does not have direct access to the level of information needed to determine the DER’s eligibility to participate and must coordinate with the EDC directly for this information. This circular information problem will continue to exist until a single data and information-sharing platform is created to allow simultaneous review of information. Until this occurs, the best placement for the RERRA review is on Day 11, directly after the EDC eligibility review.
Entergy Services, LLC., on behalf of the Entergy Operating Companies, has forwarded a markup of MISO's proposed Tariff language, with embedded explanatory comments, to MISO Shareholder Relations for posting to this feedback page.