DERTF: Order 2222 Coordination Conference (20241118)

Order 2222 Coordination – Feedback Due 12/9/24

ITC appreciates the opportunity to provide feedback on the topic of how TOs could be impacted by the coordination between Load Serving Entities and MISO when DER entities are looking to participate in the wholesale market. We also offer an idea for the February 2025 workshop. We think it would be valuable to have parties work through scenarios jointly as part of a project implementation process.  This could be structured as a separate work effort (but the topic could be introduced in the Feb 2025 workshop). For example, a walkthrough of a registration process, a study process, and a bid or self-commit process, a MISO dispatch process, meter data polling, data reconciliation and settlement process set of workstreams are necessary so that all communications and data needed to accomplish these functions can be identified, and ownership, responsibilities, interfaces, access, timeframes, etc. worked out. A discussion of outage scheduling (no changes anticipated for TOs) may also be useful. For example, if an outage were to impact a potential injection bus for a DER Aggregation, how would the DER Aggregator find out? Lots of details to be considered moving forward.

Regarding the slide in the presentation MISO presented at the 11/18/24 DERTF (included below), TOs are supposed to:

• Understand DER flows at the EP Node level
  • ITC Comments:
  • TOs do not use EP node terminology. Would MISO be able to provide a mapping tool that links EP Nodes to network model names? It seems like this should be straightforward as EP Nodes are ‘derived from’ network model names.  Additionally, there should be a mechanism to differentiate between DER that is just connecting to the electric grid verses the DER Aggregations which can include both DER generators along with demand response load.
  • For TOs to model injections on the Bulk Electric System, maximum injection by transmission level bus—worst case scenario, as well as anticipated operational injections for the timeframe under study will be needed. We anticipate that this would be provided form the distribution companies or MISO to ITC. Is this the anticipated data flow? Also, what format will be used for the data? Common Information Model conventions would ensure consistency for use and understanding across the broader stakeholder community.
  • We have additional thoughts on gaps if the information identified in the preceding bullet is what is envisioned.
    • While LSEs are anticipated to be able to identify the nameplate of the generation that connects to their distribution systems, they won’t know the unit’s output on an hour-by-hour basis. This is a gap that should be remedied to provide situational awareness to involved parties. However, we recognize that this may not be possible in some cases due to cost concerns that have been raised in the past by participants.
    • Below, we reiterate points we have raised through the years of the Order 2222 work group process:
      • Because multiple technologies are allowed to comprise a single DER Aggregation, data needs to be provided to facilitate study of, and the planning for, the operational complexities such aggregations could create on the system. Therefore, we suggest that Aggregators be required to provide information for all the technologies comprising a single DER Aggregation under a variety of different operational scenarios to MISO, the LSE, and the TO. For example, one scenario for a DER Aggregation comprised of generation, demand response and storage could be: generator at full output, demand response not operating (meaning all the demand response participants at full load consumption), and storage at full charging. Another scenario for the same DER Aggregation could be similar but with storage also fully discharging. Importantly, guardrails also need to be strengthened for the modification of DER Aggregations after they are registered. Modifications, including additions, subtractions or substitutions may require additional studies by MISO, LSEs, and TOs to understand the impact of the modifications on the system. 
      • If the Aggregator has multiple DER Aggregations in a single LSE area, the scenarios above could potentially be combined to identify the worst case of multiple aggregations operating at the same time with differing system load levels. Also, at some point, multiple DER Aggregators may be in an area, either in a single LSE or neighboring LSEs, and future needs may demand different scenarios from multiple Aggregations across LSEs be studied simultaneously.
      • Once connected, in operation and participating in MISO markets, DER Aggregators should be able (and required) to provide the LSEs with their anticipated system load (charging of batteries or station power) and generation on an hourly basis at each connection point (including anticipated operation of self-committed elements) on a Day-Ahead and potentially Hour-Ahead basis, for each DER Aggregation.  Additional forecasting by Aggregators may be needed based on changing NERC requirements. LSEs should anticipate being able to provide a roll up of this information to the relevant network nodes to the TOs for study and operations upon request. 
      • Metering requirements for DER Aggregations should align with metering requirements for resources connected at the BES level—because DERs when operating, are competing with generation at the wholesale level and data provided should be similar--to facilitate parity in settlement, operational performance and analysis.
• Plan a Reliable Transmission System
  • ITC comments:
  • Does MISO envision something beyond current requirements for this? What additional thoughts are behind including this as a requirement?
• Coordinate the Transmission Distribution Interface
  • ITC comments:
  • ITC in general agrees that it should coordinate with its LSEs as necessary to serve their identified load and distribution connected generation.  ITC believes this information should be identified in MISO’s Model Building requirements identified for MOD-032. 
  • A list of specific information, including data flows and communication paths, for DER Aggregations that MISO envisions should also be identified.  This is not information that would be typically provided to TOs through the MOD-032 process.
  • What information for DER Aggregations will be provided to TOs, by whom, and in what timeframe? What information for DER Aggregations are TOs anticipated to have to provide to distribution companies or MISO, and in what timeframe? 
  • ITC does not anticipate needing to coordinate with DER Aggregators, as their connection to the grid exists at the distribution level. Thus, ITC anticipates that any information flows to us will come from the distribution companies, or MISO as they will have access to information from DER Aggregators due to their agreements.

The slide being referenced above and below is slide #4 titled "FERC has called for collaboration across jurisdictions and seams; successful implementation requires developing new frameworks" and is located at:  https://cdn.misoenergy.org/20241118%20DERTF%20Item%2003%20OMS%20and%20MISO%20Coordination%20Discussion661035.pdf

Relative to the structure of this slide (which we tried to include but this interface does not allow pasting a picture) at one of the DERTF meetings, MISO identified that it had two separate processes--the first process was to ensure that DER entities were reliably connected to the electric grid. This was identified as being completed through the Affected System study. Once connected, both DER and demand response could propose to participate in a DER Aggregation - the Order 2222 study process.

The chart on the slide referenced above seems to have possibly merged the two as identified under the EDC list - see bullet 3 under EDC. This should perhaps be modified to: Confirm as proposed DER Aggregations can be operated reliably, including identifying any system upgrades if necessary.

Thank you,

Marguerite Wagner

ITC

Director Regulatory - Energy Markets & Innovation

mobile  512-931-9845

email  mwagner01@itctransco.com
www.itc-holdings.com | www.modernizethegrid.com

27175 Energy Way | Novi, MI 48377

DTE Electric appreciates the opportunity to provide feedback on the Order 2222 Coordination Conference.

1. What discussion areas would be most useful in preparing for Order 2222?

DER Enrollments

It is currently unclear what process MISO will use to notify LBA/LSE about DER enrollments. EDCs performing the LBA/LSE role must design several activities in response to DERs located in their service territory joining MISO.

• We believe that MISO has not yet established a formal process for notifying LBA/LSE of distributed ESR enrollments to MISO, despite being FERC Order 841 compliant.
• Is it appropriate to assume that MISO will establish a process similar to DR enrollment notifications via the MISO Demand Resource Tool (DRT)?

The process of bringing a DER to participate in MISO involves multiple steps under various authorities and may take an extended time (EDC Interconnection, MISO Enrollment, AFS, EDC Wholesale Distribution Agreement, etc.). There is an opportunity to make this process efficient by documenting roles and responsibilities at each step and setting clear expectations for all parties. This is an area where OMS could potentially take the lead.

DER Operations

The primary focus of EDCs is on the safety and reliability of the distribution system. In situations where there is a lack of confidence about a DER, due to insufficient time to study system impacts, an EDC may make a real-time decision to prevent any injecting generation to protect the grid. This may conflict with MISO participation by a DER and cause financial losses for DER Aggregators, followed by customer complaints.

• It would be beneficial to discuss recourse when a DER causes a grid issue (or a risk of a grid issue) or does not come offline as requested, from both a financial and regulatory perspective.
• The timing expectation on distribution studies is too tight. This constraint has a high probability of resulting in EDCs limiting all DER injections when a distribution circuit is abnormal for any reason.

Storm response and distribution emergency in general may impact DER’s RTO participation and even EDC’s ability to meet DER/DERA communication requirements. DTE would like to enter a discussion with MISO, OMS and other EDCs on curtailing or placing DER's online during real-time system security events.

MISO has previously stated that for communications where only one party is subject to MISO’s Tariff, FERC Order 2222 creates an obligation for communication, but execution is outside of MISO processes (see slide 4 in https://cdn.misoenergy.org/20240212%20DERTF%20Item%2003a%20Lines%20of%20Communication631746.pdf). DTE would like to initiate a discussion with MISO, OMS and other EDCs on the possible implementation of such requirements).

Metering

Will MISO Tariff metering requirements apply to DERs, ensuring all DERs and DERAs that enroll in MISO under Order 2222 must install the required metering and monitoring to ensure the reliability of the Local Distribution system and BES?

Dispute Resolution

There may be an opportunity for OMS to lead standardization in the area of dispute resolution between DER Owners, DER Aggregators, EDCs, and MISO. This applies to DER enrollment in MISO and meter data submissions. A clear, simple, and fast meter data dispute resolution process, set by MPSC, will help improve efficiency and save time for all actors (DERA, EDC). This process should include defined communication timelines between all parties (i.e., time to submit a complaint, expected response time, time to notify, time to review meter data, etc.).

Cybersecurity

• DTE believes that DER communications must meet FERC/NERC and EDC guidance for cybersecurity and resiliency.
• DER systems often include components like PV inverters that can be vulnerable to cyberattacks. If compromised, these components could disrupt the stability of the local distribution system.
• There is a concern that, lacking good utility practices, DER owners may not have robust processes to replace default passwords, install and update cybersecurity software, replace inverters and network/communication equipment, make network changes, etc.
• Another concern is related to the security of communication channels between DER systems and control centers. If intercepted by attackers, altered transmitted data may potentially lead to incorrect operational decisions.
• Unauthorized changes to DER configurations or compromised software patches can lead to system malfunctions or vulnerabilities.
• For each connected device, there needs to be a defined protocol for behavior in the event of a loss of communications or the probability of being compromised.

3. Do you have potential questions for the February 18, 2025, Order 2222 Conference?

• What is MISO’s view on which entity will serve the role of Data Administrator for the framework on slide 4?
• How does IMM see their role with DERs in MISO? What is IMM’s view on their role with DERs not following EDC’s directions and creating potential issues for the grid?

Advanced Energy United appreciates the opportunity to submit these comments in response to the Midcontinent Independent System Operator, Inc.’s (MISO) request for stakeholder feedback on the upcoming Order 2222 Coordination Conference co-sponsored by MISO and OMS, following the November 18, 2024 Distributed Energy Resources Task Force meeting.

               Advanced Energy United is a national association of businesses making the energy we use secure, clean, and affordable. Advanced Energy United is the only industry association in the United States that represents the full range of advanced energy technologies and services, both grid-scale and distributed. Advanced energy includes energy efficiency, demand response, energy storage, wind, solar, hydro, nuclear, electric vehicles, and more. The comments expressed in this submission represent the position of Advanced Energy United but may not represent the views of any particular member. 

• What discussion areas would be most useful in preparing for Order 2222?
  • Process for data sharing including privacy, cybersecurity, and costs as well as how to automate/streamline. Also what information needs to be shared – would a flow chart building off the roles graphic below be helpful including timing/deadlines?
  • Any recommended changes to registration process?
  • What other steps are needed for DER aggregation enrollments to begin by 9/01/2026?
  • More clarity around the rationale for maintaining the 1 MW size threshold for the DRR Type 1 option.

• Do you have potential questions for the February 18, 2025, Order 2222 Conference?
  • What are the expectations for measurement and verification (M&V) of impacts for settlement and for valuation? Who will be responsible for measurement and verification; and will MISO adopt standards or protocols for M&V?

• Are there specific subject matter experts that you recommend receive an invitation?
  • We recommend that parties from each of the roles/entities listed in slide 4 of Item 03 be present for a holistic conversation at the 02/18/2025 workshop.

Advanced Energy United appreciates the opportunity to provide these comments and looks forward to continuing to work with MISO on Order 2222 implementation and coordination. Please reach out to Lisa Barrett with any questions.

Respectfully submitted,

Lisa Barrett

202.380.1950 x3177

lbarrett@advancedenergyunited.org

MISO DISTRIBUTED ENERGY TASK FORCE (DERTF)

COMMENTS OF KATHAN ENERGY CONSULTING

Kathan Energy Consulting thanks MISO for the opportunity to provide feedback on the DERTF Order 2222 Coordination Conference planned for February 18, 2025. 

Kathan Energy Consulting is a small consultancy dedicated to the development of sound economic and technical distributed energy resource policy.  Since Kathan Energy Consulting’s President, Dr. David Kathan, was the lead analyst at FERC on Order 2222 prior to his retirement at the end of 2022, implementing FERC Order 2222 is a key part of Kathan Energy Consulting practice.  The primary purpose of these comments is to highlight important FERC Order 2222 implementation issues related to coordination that should be covered in the Coordination Conference. 

COMMENTS 

Kathan Energy Consulting limits its response to the first and last questions listed on the DERTF request for stakeholder input, as follows:  

What discussion areas would be most useful in preparing for Order 2222? 

Kathan Energy Consulting recommends that the Order 2222 Coordination Conference planned for Feb. 18, 2025 include an in-depth discussion of the following issues:

• Possible protocols, standards, and communication methods for coordinating DER aggregation dispatch by MISO, particularly when distribution network constraints or unexpected outages affect the operation of individual DERs – see the multiple references to coordination on page 4 of DERTF’s “O2222 Coordination Framework Plan” presentation (dated Nov. 18, 2024)
• Data and information sharing as described on page 5 of the DERTF’s O2222 Coordination Framework Plan. 

 Are there specific subject matter experts that you recommend receive an invitation? 

Kathan Energy Consulting is pleased to offer its President, Dr. David Kathan, as a subject matter expert on FERC Order 2222, particularly on (a) coordination necessary RTOs/ISOs, electric distribution companies, state and local regulators, and DER aggregators, and (b) data sharing rules and the use of common DER data sources.  

Respectfully submitted:  

David Kathan, Ph.D.

President 

Kathan Energy Consulting 

4920 Dorset Avenue 

Chevy Chase, MD 20815

Telephone: (301) 461-7252 

david@kathanenergy.com  

December 9, 2024