IPWG: Recommended IBR Performance Requirements (PAC-2024-2) (20240723)

At the July 23 IPWG meeting, MISO presented updates to the proposed Generator Interconnection Agreement Appendix G requirements pertaining to inverter based resources.  The MISO Transmission Owners (Owners) appreciate MISO advancing footprint wide requirements related to IEEE 2800. 

The Owners support following the PRC-028 standard development and not implementing GIA Appendix G language that could not align with the data recording requirements in the standard.

The Owners support the implementation of these requirements as soon as practical and support applying them to the DPP-2023 cycle.

August 14, 2024

Orsted Onshore North America’s (Orsted) Feedback on July 23, 2024, Presentation on Recommended IBR Performance Requirements (PAC-2024-2) to Interconnection Process Working Group

Please accept the following comments in response to the July 23, 2024 presentation on inverter -based resource performance requirements as related to IEEE 2800 phase II adoption.  Additional discussion and detail is needed related to the proposed requirements for reactive power capabilities at zero and consecutive voltage deviation ride-through.

reactive power capability at zero active power:

MISO should not adopt the IEEE 2800 proposal to provide reactive power when the resources is not generating power at this time.  Producing or absorbing reactive power at zero active power is not a default option for certain wind turbine generators as there is an additional cost to the generator associated with providing this service.  This places a significant burden on the generation owner.  This would be consistent with the language in IEEE 2800 that while market and economic factors are outside the standards scope, they may need due consideration.  The issue of compensation associated with paying for this service is currently before the Federal Energy Regulatory Commission and MISO should defer adoption of the standard until that docket is completed and then have a discussion if needed on economic factors.  

consecutive voltage deviation ride-through:

There are a number of issues associated with consecutive voltage ride through requirements that are not addressed in IEEE 2800.  In determining implementation, MISO should consult with vendors and manufacturers to determine what requirements would be reasonable.  These issues include:

• Compliance testing: Can MISO specify the compliance test procedures for the plant and the unit to demonstrate compliance with the IEEE-2800 requirements?
• Consultation with OEM: Has MISO consulted with the WTG and inverter (PV/BESS) vendors who can provide attestation of their IBR unit meeting the consecutive fault ride through requirements?
• Hardware limitation exemption: MISO should include language exempting technologies that have documented hardware limitations and as a result are unable to meet the consecutive fault ride through? Alternatively,  MISO could clearly define the combination of multiple faults that they would realistically see on their transmission system and limit the scope of consecutive faults to these likely events.
• Conflicts with reliability and newer technology (like GFM): Could site-specific parameters, which are designed to enhance the grid's stability, supersede MISO’s proposed fault ride through requirements?
• Clarifying vendor/equipment tests and attestations upfront to the developer: Can MISO specify what vendor/OEM documentation a developer must provide at different stages of the interconnection process and if the OEMs can deliver these before the 2026 GIA timelines.

In determining what IEEE 2800 standards should be adopted and how they should be implemented, Orsted encourages MISO to consider the rationale for the need within their system.  Orsted appreciated the opportunity to comment on this important issue.