IPWG: Recommended IBR Performance Requirements (PAC-2024-2) (20240312)

For the IPWG IBR performance requirements and the PMU data requirement:

• We agree with proceeding with IEEE 2800 adoption.
• Please concentrate on specifying capabilities and avoid requiring specific equipment such as PMUs.
• Please specify where entities have existing meters and equipment that can meet IEEE 2800, they be allowed to use the existing equipment.

DTE appreciates the opportunity to provide feedback on MISO’s proposed performance requirements for adoption covering voltage and frequency support, consecutive voltage deviation ride-through, and measurement.   We have the following questions and concerns:

1. Regarding the Voltage Control Response times:  
1. When using a PPC or MPPC to control the voltage of a wind, solar, or hybrid site using a PPC or MPPC (hybrid), the latency in the system would not permit the site to achieve a reaction time of <200ms.
2. The PPC or MPPC is located in the substation control house and the PV inverters or wind turbines could be several miles away.
3. We will have to discuss with inverter and wind turbine OEMs if it’s possible to configure their equipment such that in the event of a voltage excursion, the equipment would automatically respond without a setpoint input from the PPC or MPPC.

1. As a general note, DTE has received feedback from the Vendors that the current models of wind turbines do not meet many of the IEEE 2800 requirements.
1. There was no timeline provided for when a new compliant model would be available.
2. This could have a significant impact on the projects with IBRs that are coming in the next 3-5 years.

We would like for MISO to address the concerns that we have listed above and we look forward to further discussion on this very important topic.

Arevon appreciates the opportunity to provide feedback on MISO’s proposed IBR performance requirements.

Generally speaking, Arevon thinks that MISO has appropriately identified the performance requirements on which it should move forward (Slide 5 of MISO’s March 13, 2024 presentation at the IPWG – “Presentation”).  There are a couple of specific points Arevon would like to make.

First, with respect to the maximum step response time within the suggested range of 1 – 30 seconds (Slide 8 of the Presentation), Arevon believes that MISO should start with 30 seconds.  Since these will be new requirements, MISO should start conservatively and make future adjustments as necessary and feasible.

Second, with respect to the reaction time performance target of less than 200 ms, not all IBR resources can achieve this (DC coupled battery storage systems, for example).  MISO should be careful not to establish across the board IBR requirements that can’t be met by all IBR resource types.

Savion, LLC (“Savion”), a Shell Group portfolio company, is an industry-leading utility-scale solar and energy storage project development company. Savion appreciates the opportunity to provide input on “Recommended IBR Performance Requirements (PAC-2024-2)”. Savion agrees and support the implementation of IEEE2800. However, Savion would like some clarification on this matter.

• • • When is MISO planning on implement the new requirement?
    • What DPP cycle is MISO considering on implementing the IEEE2800 rules?
    • Has MISO coordinated the implementation of IEEE 2800 with major inverter manufactures? If so, have they raised any concern?

• AES Renewables appreciates the opportunity to comment on Phase 2 of the IEEE 2800 implementation. AES is still in the process of investigating the standard and ability of various inverter manufactures to comply with these requirements. The comments below reflect our understanding to date, but we look forward to providing MISO with more specific feedback as we continue our own research. In light of this uncertainty on timing and potential availability of compliant inverters, AES recommends that MISO adopt similar provisions as they did in Phase 1 that allow project developers to delay compliance if they can provide evidence of the inability to procure (or procure at necessary scale/timeline) inverters that are compliant with IEEE 2800 requirements as adopted. AES recommends that these reforms only apply to cycle 2024 projects at the earliest since there will be a higher likelihood of ability to procure compliant inverters in 2026 and beyond.
• MISO should also provide flexibility in requirements to submit inverter models at the time of application and while in queue. The stringency of providing compliant models at the time of application should determine which interconnection cycle these requirements are effective for. It is AES’s understanding that currently there are no inverter manufacturers that can provide models that meet the IEEE 2800 requirements, and that these may not be available until the end of 2024 at the earliest. If MISO wants to implement these requirements sooner, for example for cycle 2023 projects, it should provide interconnection customers flexibility in submitting models that reflect IEEE 2800 requirements during the interconnection study process and allow customers to update these models once they become available. The submission of these updated models should not impact their queue position as currently contemplated in Order 2023. If MISO intends to strictly enforce the modeling requirements outlined in Order 2023 and deem any changes to those models as a withdrawal offense, MISO should only apply the IEEE 2800 requirements to projects once compliant inverter models are widely available.
• AES seeks further clarification of several statements on Slide 8 before it can provide input. First, the bullet point that states “defining the range of system conditions for which dynamic performance requirements are applicable” does this suggest the performance requirement might change as grid conditions change? If so, under what conditions would this requirement change? Will project owner operators be expected to track system conditions to know what performance requirements are applicable? How will the grid operator notify project owners of when these change? On the same slide, the table in the upper right says, “Maximum step response time: As required by the Transmission System (TS) operator.”  Is the related to the same point above? AES is interpreting this to mean only the TS operator, not IEEE 2800, can determine what the best max step response time should be, based on the specifics of their system. That is, this is a performance target that is set once and does not vary with system conditions. Can MISO clarify how these two bullets on slide 8 relate to each other?
• In regard to specific constant power factor control mode requirements, AES is still researching inverter capabilities to support this requirement. AES encourages MISO to also talk with manufactures about what is possible. AES may have more specific feedback on this item as we complete our outreach and research.
• In regard to measurement data categories and requirement of PMU data, AES request clarification on whether MISO is proposing to require streaming or storing of all PMU data, rather than only in response to a disturbance? If so, this could create a significant impact on generators in terms of bandwidth requirement of networks and capability of local storage. Additionally, some of the transient data recording requirements may be too specific around the “how” of this requirement should be implemented. Inverters and plants can meet all the standard requirements in terms of behavior and controls without having to get to the level of microsecond data recording specified, and there are some challenges around synchronizing data across all the plant devices at the level and in the way the standard suggests, which could make compliance more difficult. MISO should consider additional flexibility if plants are able to meet the spirit of this requirement.

Transmission Owners Feedback on Inverter-Based Resource Performance Requirements

March 29, 2024

At the March 12, 2024 meeting of the Interconnection Process Working Group (IPWG), MISO requested the following feedback on proposed IBR Performance Requirements:

• Concerns or reasons not to proceed with recommended performance requirements
• Other performance requirements you see as priorities to be included in the first round of implementation

• Specific input on the following technical questions, with rationale for preferences:
• What voltage control maximum step response time, within the range of 1-30 seconds, is preferred?
• What is the preferred methodology for defining the range of system conditions that the voltage control dynamic performance requirements should be applicable for?
• What is the preferred minimum active power level for power factor control mode operation?
• Concerns about implementation of consecutive voltage deviation ride-through requirements
• Thoughts on measurement data categories and requirement of PMU data

The MISO Transmission Owners (TOs or Owners) appreciates MISO’s efforts to establish footprint wide requirements for Inverter-Based Resource Performance, as many Owners already have established these requirements, and consistency in both the requirements and the execution of these requirements throughout the footprint would be a welcome improvement to both the Generator Interconnection Process and the accuracy of transmission planning models. In response to the questions posed by MISO in the IPWG Stakeholder Feedback Request, the Owners offer the following:

• Concerns or reasons not to proceed with recommended performance requirements

The Owners support MISO’s proposal to update its basic Inverter-Based Resource Performance Requirements to incorporate the IEEE P2800 Standard, the Owners agree with MISO’s overview of the issue and support MISO’s program. While many Transmission Owners’ Planning Criteria addresses these issues the Owners would prefer MISO-wide requirements and consistent execution.

• Other performance requirements you see as priorities to be included in the first round of implementation

1. The Owners encourage MISO to adopt most extensive requirements that they can due to the increasing penetration of IBRs and the increased risk to the System.
2. MISO and stakeholders should define the term “online” (referenced on slide 6). The Owners recommend:

When the Generating Facility is physically connected to the transmission system and the breakers are closed

3. MISO should include specific language around what solar generation can and cannot do during night hours (e.g. can they disconnect from the grid).

For the specific technical questions posed by MISO, the Owners provide the following recommendations:

• What voltage control maximum step response time, within the range of 1-30 seconds, is preferred? (Slide 8)
• Local planning criteria should govern the voltage control maximum step response time.
• If the IBR is connecting in a weak grid then the response time needs to be longer so as to meet the damping requirement. MISO should adopt the generic time of 1-30 seconds and the local TO’s can provide a different response time depending on the location.
• Specific example of LPC in a stronger grid:

• Recover to above 0.7 pu <1 second following the fault clearing.
• Recover to .8 pu – <2 seconds following fault clearing.
• Recover to 0.90. p.u. < 10 seconds.
• Recover below 1.2 p.u. <1 second following the fault clearing.

• What is the preferred methodology for defining the range of system conditions that the voltage control dynamic performance requirements should be applicable for?
  • Voltage control dynamic performance requirements should be applicable to NERC TPL-001-5 category P0 (steady-state) and P1-P7 contingency events.
  • If applicable, NERC TPL-001-5 extreme events must show recovery (20-30 sec), but not limited to maximum response time defined above.

• What is the preferred minimum active power level for power factor control mode operation?

• In the first round of implementation, MSIO should require IBRs to provide power factor control at all power levels, including Zero MW output.
  • Because IBR units already connected on our systems may require a minimum power level to provide control, some TO systems have observed high voltages during low load at night when reactive power input is produced from IBR collector systems.
  • Generating facilities should zero out reactive power injection to the transmission system at zero MW output.

• Concerns about implementation of consecutive voltage deviation ride-through requirements
• No concerns
• Thoughts on measurement data categories and requirement of PMU data
• The Owners support using PMU data for meeting DDR data requirements.
• More information is needed on MISO proposal for data streaming versus data storage to respond to this question – for example we recommend MISO determine the type of data to be collected.

Finally, communication of a generator going into service is necessary. This communication is the trigger for requirements such as: Schedule 50 Charges, 345kV upgrade reimbursements, updated models and protection settings due to TO within 60 days of commissioning (often not delivered timely or at all when requested by the TO, and NERC registration requirements and associated obligations (e.g. MOD, PRC). In general, communications with ICs regarding the transfer of necessary data associated with the IBR’s final design and subsequent changes becomes more difficult once the GIA has been executed. Most importantly, MISO needs to verify that any performance requirements established here are incorporated in the steady-state and stability models during the DPP pre-queue phase and the stability study during DPP Phase 2. Such requirement verification should include Q-priority flag setting, active and reactive power response and settling times, and elimination of momentary cessation, among other model verification checks against the proposed requirements. In addition, these requirements should be verified with the as-built specifications once the generator has reached Commercial Operation.

Both ATC and Entergy have specific IBR requirements posed publicly available:

• ATC Planning Criteria is posted at:

https://cdn.misoenergy.org/ATC%20TO%20Planning%20Criteria108210.pdf see Sections 2.1c,

3, and 4.

• Entergy’s Interconnection and Operating Guides for Inverter-Based Resources is posted at:

https://cdn.entergy.com/userfiles/content/operations_information/transmission/fcr/IBR.pdf