Michael Kessler
`Assistant General Counsel
`Direct Dial: 317-249-5290
`E-mail: mkessler@misoenergy.org
`
`
`
`
`
`April 14, 2022
`
`VIA ELECTRONIC FILING
`
`The Honorable Kimberly D. Bose
`Secretary
`Federal Energy Regulatory Commission
`888 First Street, NE
`Washington, DC 20426
`
`Re: Midcontinent Independent System Operator, Inc.
`
`Order No. 2222 Compliance Filing
`Docket No. ER22-___-000
`
`Dear Secretary Bose:
`The Midcontinent Independent System Operator, Inc. (“MISO”), through this filing,
`hereby submits its proposed revisions to its Open Access Transmission, Energy and Operating
`Reserve Markets Tariff (“Tariff”)1 in compliance with the Federal Energy Regulatory
`Commission’s (the “Commission”) Order No. 2222.2 MISO respectfully requests that the
`Commission accept this filing in compliance with the requirements of Order No. 2222.
`
`As discussed below, MISO proposes an effective date of October 1, 2029 for the Tariff
`revisions necessary to implement the requirements of Order No. 2222. Consistent with Order No.
`2222’s direction, MISO has evaluated the unique needs of its stakeholders as a whole, along with
`MISO’s market systems, software, and measures, to address reliability in the MISO Region. Based
`on this evaluation, MISO has determined that the October 1, 2029 effective date is a reasonable
`implementation date for the MISO Region.3
`
`
`
`1 MISO submits these amendments pursuant to Section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d,
`and Section 35.12 of the Federal Energy Commission’s (“FERC” or “Commission”) regulations, 18 C.F.R.
`§ 35.12 (2018). All capitalized terms in this filing not otherwise defined have the same meaning as they have
`under the current MISO Open Access Transmission, Energy and Operating Reserve Markets Tariff (“Tariff”).
`2 Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission
`Organizations and Independent System Operators, 172 FERC ¶ 61,247 (2020) (“Order No. 2222”).
`3 See Order No. 2000 at P 361 (“Based on comments submitted about the complexity of changes to RTO/ISO
`market rules and system, we [FERC] will not require the implementation of the tariff provisions within 12 months
`from the date of the compliance filing, as proposed in the NOPR. Instead, we will require each RTO/ISO to
`propose a reasonable implementation date, together with adequate support explaining how the proposal is
`appropriately tailored for its region and implements this final rule in a timely manner. The Commission will
`establish on compliance the effective date for each RTO’s/ISO’s compliance filing.”).
`Midcontinent Independent
`System Operator, Inc.
`317.249.5400
`www.misoenergy.org
`
`2985 Ames Crossing Road
`Eagan, MN 55121
`
`1700 Centerview Drive
`Little Rock, AR 72211
`
`720 City Center Drive
`Carmel, IN 46032
`
`
`
`
`

`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 2
`
`Given the complexities of this compliance proposal, MISO requests that the Commission
`
`extend the standard twenty-one (21) day comment period to June 6, 2022. This extension will
`provide MISO stakeholders and other interested parties sufficient time to develop responsive
`pleadings in this matter.
`
`
`EXECUTIVE SUMMARY
`I.
`
`MISO’s vision to be the most reliable, value-creating RTO requires careful analysis of the
`current and future state of the MISO Region, including markets, transmission planning, operations,
`and software system needs. Through this analysis, MISO has recognized the shared responsibility
`that MISO, its members, and Relevant Electric Retail Regulatory Authorities (“RERRAs”) have
`to address the urgent and complex challenges to electric system reliability in the MISO Region.
`Collectively, MISO refers to this shared responsibility as the “Reliability Imperative.”4 In
`collaboration with stakeholders, MISO has used the Reliability Imperative to identify and prioritize
`its efforts to address the reliability impacts of significant shifts in the generation fleet in the MISO
`Region resulting from retirement of baseload resources and increased reliance on intermittent
`resources, such as wind and solar as well as the system impacts associated with more frequent and
`extreme weather conditions.
`
`The efforts necessary to respond this Reliability Imperative has been organized into four
`main areas: (1) Market Redefinition; (2) Long Range Transmission Planning; (3) Operations of
`the Future; and (4) Market Systems Enhancements (“MSE”). MISO has well documented in other
`filings with the Commission the need to replace the legacy software and systems currently relied
`upon to operate the Transmission System and administer its energy and operating reserves markets.
`This effort is being address through MISO’s MSE project. While the MSE project is well
`underway, the ultimate completion of the new software and systems installation is not expected
`until the end of 2024.
`
`Through discussions with stakeholders and internal analysis, MISO has prioritized certain
`projects for implementation immediately after MSE completion. These projects have been delayed
`for years pending MSE completion and will have an immediate impact, delivering quantifiable
`reliability and economic benefits to the MISO Region. In particular, MISO’s proposed
`prioritization of the Multiple Configuration Resources (“MCR”) initiative is expected to provide
`reliability benefits by providing operational flexibility needed to manage the MISO Region’s
`increased reliance on intermittent resources, such as wind and solar, to meet the region’s baseload
`demand needs. In addition, MCR is expected to deliver between $14 million and $34 million
`annually in production cost savings resulting from more efficient management and dispatch of
`Combined Cycle Gas Turbines (“CCGTs”), which comprise approximately 18.3% of MISO’s
`installed capacity as of the 2022 / 2023 Planning Year. The more efficient management of MCR
`will also help the MISO Region reach decarbonization goals.
`
`While MISO recognizes the benefits of promoting distributed energy resource participation
`in its wholesale markets through the addition of distributed energy resource aggregations, the
`
`
`Imperative,
`Reliability
`the
`to
`Response
`MISO’s
`4
`available
`See
`https://cdn.misoenergy.org/MISO%20Response%20to%20the%20Reliability%20Imperative504018.pdf
`accessed Mar. 15, 2022).
`
`at
`(last
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`

`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 3
`
`benefits of these aggregations are unknown and relatively limited by the existing retail regulatory
`construct in many of the states in the MISO Region. Only three states in the MISO Region
`currently allow for retail demand resource aggregation, which could significantly limit the
`participation of distributed energy resource aggregations in MISO’s markets. Unlike MCR, the
`potential quantity of distributed energy resource aggregations, both number of aggregations and
`capacity in megawatts, is unknown.
`
`The Commission was clear in Order No. 2222 that it would not require ISOs / RTOs to
`implement Order No. 2222’s requirements by a date certain. Rather, the Commission stated that
`it would, “require each RTO/ISO to propose a reasonable implementation date, together with
`adequate support explaining how the proposal is appropriately tailored for its region and
`implements this final rule in a timely manner.”5 As discussed below and in the testimonies
`supporting this filing, MISO proposes an implementation date for its Order No. 2222 compliance
`proposal that reasonable and appropriately tailored to meet the reliability and economic needs of
`the MISO Region.
`
`II.
`
`BACKGROUND AND OVERVIEW OF COMPLIANCE PROPOSAL
`In Order No. 2222, the Commission required MISO to revise its Tariff to establish market
`rules that address coordination between MISO, the Distributed Energy Resource aggregator, the
`distribution utility or electric distribution company (collectively the “EDC”), and the RERRA.6
`Additionally, with respect to operational coordination, the Commission required MISO to: (i)
`establish a process for ongoing coordination, including operational coordination, that addresses
`data flows and communications among itself, the DER aggregator, and the distribution utility; (ii)
`require the DER aggregator to report to MISO any changes to its offered quantity and related
`distribution factors that result from distribution line faults or outages;7 (iii) include coordination
`protocols and processes for the operating day that allow distribution utilities to override MISO’s
`dispatch of a DER aggregation in circumstances where such override is needed to maintain the
`reliable and safe operation of the distribution system;8 and (iv) apply any existing non-performance
`penalties to DER aggregators when they fail to perform as a result of override.9 The Commission
`also required that MISO revise its Tariff to incorporate dispute resolution provisions as part of its
`proposed EDC review process.
`The following subsections provide an overview of MISO’s compliance proposal as it
`relates to the Commission’s directives of Order No. 2222. Discussion of the specific Tariff
`revisions submitted in this filing is provided in Section IV below, and additional support for
`MISO’s compliance proposal is provided in the testimonies of Mr. Richard Doying, Mr. Todd
`Ramey, and Ms. Laura Rauch submitted herewith.
`
`
`
`5 Order No. 2222, P 361.
`6 Id., P 278.
`7 Id., P 310.
`8 Id., P 312.
`9 Id., P 312.
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`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 4
`
`
`A.
`
`DER Aggregator as Market Participant
`1.
`Commission Directive
`In Order No. 2222, the Commission required MISO to have Tariff provisions that allow
`DER aggregations to participate directly in MISO’s markets, and establish DER aggregators as a
`type of Market Participant.10
`2.
`MISO Proposal
`A Distributed Energy Resource Aggregator (“DERA”) will be a new Market Participant in
`MISO, able to submit offers in MISO’s Energy and Operating Reserve Markets.11 DERAs will be
`eligible to register and enroll Distributed Energy Aggregated Resources (“DEAR”).12 DEARs are
`a new resource type developed to accommodate aggregation of heterogenous Distributed Energy
`Resource aggregations, as described further below. As more fully described in the Testimony of
`Ms. Laura Rauch, MISO’s formal process begins with the registration of the DERA as a Market
`Participant, following which the DERA may begin the process of enrolling their DEAR.13 The
`registration process will include a review to ensure there is no wholesale / retail dual compensation,
`reliability reviews from the EDC, and MISO including the DEAR in the commercial model.14
`DERAs will be required to execute MISO’s Market Participant Agreement, Attachment W to the
`MISO Tariff, to participate in MISO’s markets.15 The relationship with the DERA as a Market
`Participant will be similar to any other relationship between MISO and Market Participants that
`represent multiple assets in MISO’s markets today in that MISO will not have a direct contractual
`relationship with the individual assets (DEAR) represented by the DERA.16
`MISO has revised Module A – 1.D and Tariff Sections 38.3.3, 38.2.5 and 38.7 to address
`the Commission’s directive.
`B.
`The Distributed Energy Resource Aggregation Participation Model
`1.
`Commission Directive
`In Order No. 2222, the Commission required MISO to allow DER aggregators to register
`DER aggregations under one or more participation models in MISO’s Tariff that accommodate the
`physical and operational characteristics of the DER aggregation.17 The Commission explained that
`MISO may comply with this requirement by: (i) modifying its existing participation models to
`facilitate the participation of DER aggregations; (ii) establishing one or more new participation
`models for DER aggregations; or (iii) adopting a combination of those two approaches.18
`
`
`
`10 Order No. 2222 at PP 129-130.
`11 Proposed Tariff Section 38.3.
`12 Proposed Tariff Section 38.7.
`13 Rauch Testimony at 28. Also as noted in the Testimony of Ms. Rauch, the registration and enrollment processes are
`referred to collectively as “registration” for purposes of this filing. Id. at 26-27.
`14 Id.
`15 Id. at 45.
`16 Id. at 45.
`17 Order No. 2222 at PP 129-130.
`18 Id.
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`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 5
`
`
`MISO Proposal
`2.
`MISO’s Order No. 2222 compliance proposal establishes a new participation model for
`Distributed Energy Resource aggregations. To facilitate the new participation model, MISO has
`developed a number of new definitions, including: (1) Distributed Energy Resource (“DER”),
`which are the individual resources that comprise aggregations; (2) Distributed Energy Aggregated
`Resources (“DEARs”), which represent one or more Distributed Energy Resources and participate
`in an aggregation as a single Resource in MISO’s markets; and (3) Distributed Energy Resource
`Aggregators (“DERAs”), which are the Market Participants that represent Distributed Energy
`Aggregated Resources in MISO’s markets.19
`As described in detail in the Testimony of Ms. Laura Rauch, MISO’s proposed DER
`participation model will allow DERAs to participate in applicable MISO markets based on the
`services that the DEAR(s) represented by a DERA are technically capable of providing.20 DEARs
`will be able to participate in MISO’s Energy and Operating Reserve Markets through a single
`Elemental Pricing Node (“EP Node”) utilizing self-commitment under normal conditions while
`having the potential to be called on by MISO during emergency conditions.21 In addition, DEARs
`may participate as a Capacity Resource in MISO’s annual Planning Resource Auction (“PRA”).
`Ms. Rauch’s Testimony provides further detail on the manner in which a DEAR may participate
`in MISO’s Resource Adequacy construct, including the manner in which such resource will be
`accredited and applicable deliverability and replacement requirements.22
`MISO has revised Module A – 1.D and Tariff Sections 38.7, 38.2.2, 39.1.2, 39.2.1A,
`39.2.5E, 40.2.3, 40.2.7C to address the Commission’s directive.
`C. MISO’s proposal does not prohibit any particular type of DER technology
`from participating in DER aggregations and allows for heterogeneous DER
`aggregations.
`1.
`Commission Directive
`
`In Order No. 2222, the Commission required that MISO’s rules not prohibit any
`
`particular type of DER technology from participating in DER aggregations, and that MISO revise
`its Tariff to allow different types of DER technologies to participate in a single DER aggregation
`(i.e., allow heterogeneous DER aggregations).23
`
`2.
`MISO Proposal
`MISO’s DERA participation model allows for heterogenous aggregations and does not
`limit aggregations to a particular technology. As such, MISO’s proposal is consistent with Order
`No. 2222’s requirement that MISO’s rules not prohibit any particular type of DER technology
`from participating in DER aggregations, and that MISO revise its Tariff to allow different types
`
`
`19 Proposed Tariff Module A – 1.D.
`20 Rauch Testimony at 4-5.
`21 Id. at 4-6. MISO’s support for limiting DEAR market participation to a single EP Node is further described in
`Section II. H. of this transmittal letter.
`22 Id. at 23-26.
`23 Order No. 2222 at PP 141-142.
`
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`

`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 6
`
`of DER technologies to participate in a single DER aggregation (i.e., allow heterogeneous DER
`aggregations). A depiction of MISO’s DERA taxonomy is provided below:
`
`
`Each homogeneous aggregation of Distributed Energy Resources within a heterogeneous
`
`DEAR is defined as a “DER Group.” These DER Groups will be used for settlements purposes
`and for measurement and verification, as described in the Testimony of Ms. Rauch.24 The
`following provides an example of the use of DER Groups:
`
`
`
`
`[Remainder of page intentionally left blank. Graphic appears on following page.]
`
`24 Rauch Testimony at 4, 46-47.
`
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`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 7
`
`
`MISO has revised Tariff Module A – 1.D to address the Commission’s directive.
`
`D.
`
`Allow DERs that participate in one or more retail programs to participate in
`its wholesale markets; allow DERs to provide multiple wholesale services;
`include any appropriate restrictions on DER participation in MISO’s markets
`through DER aggregations.
`
`
`
`1.
`
`Commission Directive
`
`In order to avoid duplicative compensation for the same service, and still permit
`participation in multiple wholesale, or both wholesale and retail programs, the Commission in
`Order No. 2222 required MISO to revise its Tariff to: (i) allow DERs that participate in one or
`more retail programs to participate in its wholesale markets; (ii) allow DERs to provide multiple
`wholesale services; and (iii) include any appropriate restrictions on the DERs’ participation in
`MISO markets through DER aggregations, if narrowly designed to avoid counting more than once
`the services provided by DERs in MISO markets.25
`
`25 Order No. 2222 at P 160.
`
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`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 8
`
`MISO Proposal
`2.
`
`
`Under MISO’s proposed participation model, the demand response portion of the meter
`
`data reported by the DERA will be settled under existing settlement rules developed for FERC
`Order 745 compliance. This process addresses double counting by reconstituting load and aligns
`with existing tools and processes. As discussed in the Testimony of Ms. Laura Rauch, there are
`two steps identified during the registration process to prevent double counting.26 First, the Load
`Serving Entity (“LSE”) or EDC (as applicable) will review the aggregation to ensure all proposed
`assets are eligible for the proposed wholesale compensation and are not otherwise compensated
`for these same wholesale services at retail.27 After the LSE/EDC confirms or denies the wholesale
`participation eligibility of individual assets, this review outcome and supporting facts will be
`provided to the RERRA, as the applicable retail rate authority, to confirm what is included or
`excluded in the applicable retail rate.28 This review will be performed before the DEAR Technical
`Review.29
`MISO has revised Tariff Module A – 1.D to address the Commission’s directive.
`E.
`Establish a minimum size requirement for DER aggregations that does not
`exceed 100 kW.
`1.
`Commission Directive
`In Order No. 2222, the Commission required MISO to implement a minimum size
`requirement not to exceed 100 kW for all DER aggregations.30
`
`2.
`MISO Proposal
`Under MISO’s proposed participation model, a DEAR must be physically located within
`the MISO Region (i.e., not pseudo-tied into MISO from another region)31 and may not have a
`Capacity smaller than 100 kW.32 In addition, a DEAR may register as a single Resource for
`participation in MISO’s Energy and Operating Reserve Markets, or in MISO’s Planning Resource
`Auction. In order to ensure transmission security through market-based congestion management,
`the participation model will support DER aggregations behind individual EP Nodes as the broadest
`geographic scope of aggregation. Similar to Electric Storage Resources implemented pursuant to
`FERC Order No. 841, all DEARs are self-committed under normal conditions, with limited
`exceptions, such as contingency reserve deployments and emergency declarations. This
`requirement will ensure acceptable technical performance and optimization of MISO’s market
`clearing algorithms and mitigate reliability concerns that significant volumes of DEARs would
`need to be manually committed by MISO operators in Real-Time.33
`
`
`
`26 Rauch Testimony at 30.
`27 Id.
`28 Id.
`29 Id.
`30 Order No. 2222 at P 171.
`31 Tariff Section 38.7.
`32 Tariff Module A 1.D.
`33 Rauch Testimony at 13-14.
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`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 9
`
`
`
`
`
`MISO notes that the definition of DEAR establishes that the aggregated operable capacity
`of the DER Groups must be at least 100 kW. Operable capacity includes Distributed Generation
`Resources and all Distributed Storage Resources plus the Load reduction amount from all
`Distributed Demand Response Resources; but does not include capacity associated with Energy
`Efficiency Resources. Mr. Rauch explains that the exclusion of Energy Efficiency Resources from
`operable capacity is necessary as these resources cannot be dispatched.34
`MISO has revised Tariff Module A 1.D to address the Commission’s directive.
`F.
`DER aggregations do not have a maximum size requirement.
`
`1.
`Commission Directive
`In Order No. 2222, the Commission directed MISO to propose a maximum capacity
`requirement for individual DERs participating in its markets through a DER aggregation or,
`alternatively, to explain why such a requirement is not necessary.35
`
`2.
`MISO Proposal
`As explained by Ms. Rauch, MISO will not set a maximum size for DEARs, or for
`
`individual DERs within such an aggregation.36 MISO notes that size limitations may arise due to
`RERRA policies or the physical limitations of the system in the EDC review.
`G.
`A single qualifying DER may serve as its own DER aggregator.
`1.
`Commission Directive
`In Order No. 2222, the Commission required MISO to revise its Tariff to allow a single
`qualifying DER to avail itself of the proposed DER aggregation rules by serving as its own DER
`aggregator.37
`
`
`
`2.
`
`MISO Proposal
`
`Under MISO’s proposal, a DEAR may consist of a single asset.38 As discussed in the
`
`Testimony of Ms. Laura Rauch, a DERA can elect to register a DEAR based on the capability of
`the aggregated assets or the individual asset if the DEAR consists of a single asset.39 Constituent
`assets can be Distributed Demand Response Resources, Distributed Storage Resources,
`Distributed Generation Resources and/or Energy Efficiency Resources.40
`
`MISO has revised Tariff Module A 1.D to address the Commission’s directive.
`
`
`
`34 Id. at 16.
`35 Order No. 2222 at P 179.
`36 Rauch Testimony at 16.
`37 Order No. 2222 at P 185.
`38 Tariff Module A 1.D.
`39 Rauch Testimony at10.
`40 Id.
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`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 10
`
`
`
`
`Locational Requirement for DER aggregations.
`H.
`1.
`Commission Directive
`
`In Order No. 2222, the Commission required MISO to revise its Tariff to establish
`locational requirements for DERs to participate in a DER aggregation that are as geographically
`broad as technically feasible.41 The Commission specified that MISO must provide a detailed,
`technical explanation for the geographical scope of its proposed locational requirements in its
`compliance filing.42
`MISO Proposal
`
`
`2.
`
`Under MISO’s proposal, a DEAR will be limited to units physically within the MISO
`Region.43 Pseudo-tied units will be ineligible for participation.44 DEARs must also be aggregated
`to a single EP Node for participation within MISO.45 As explained by Ms. Rauch, MISO’s analysis
`determined that aggregation at a single EP Node is the broadest and most technically feasible
`approach to model DEARs.46 This aggregation matches the granularity of MISO’s dispatch,
`allowing DEARs to be priced equivalently with other resources participating in MISO’s Energy
`and Operating Reserve Markets.47 It also provides for visibility and operational awareness,
`ensuring transmission security through market-based congestion management and MISO’s
`Security Constrained Economic Dispatch (“SCED”).48
`
`MISO considered several alternatives to its single EP Node aggregation proposal submitted
`in this filing. These alternatives included creating a market product that combined a single-node
`aggregation for dispatchable resources with a multi-node approach for resources that must be bulk
`dispatched (i.e., on/off resources) or creating clusters of EP Nodes to allow for broader
`aggregation. As discussed by Ms. Rauch, neither alternative was selected due to concerns over
`the ability to provide timely and accurate real-time distribution factors, which would require real-
`time updates on the status of the distribution system to feed into MISO’s SCED.49 Ms. Rauch
`goes on to explain that inefficiencies in the creation and accuracy of these distribution factors
`would create a paradigm where units that negatively impact congestion are paid equally to units
`that relieve a constraint, creating an untenable market solution.50 In addition, anticipated
`transmission constraint relief dispatch could adversely impact flows over constrained parts of the
`system and result in the need to dispatch other generation to avoid degraded system reliability.51
`
`MISO notes that there are currently three types of demand resources for which multi-node
`aggregations are permitted: DRR Type-1; Load Modifying Resources; and Emergency Demand
`Response resources. Each of these resources are distinguishable from DEARs in significant
`
`
`
`41 Order No. 2222 at P 204.
`42 Id.
`43 Tariff Section 38.7.
`44 Tariff Section 38.7.
`45 Rauch Testimony at 16.
`46 Id. at 18.
`47 Id.
`48 Id.
`49 Id.
`50 Id.
`51 Id.
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`
`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 11
`
`respects, as discussed in Ms. Rauch’s Testimony.52 Ultimately, MISO’s single EP Node
`aggregation approach is consistent with a joint report issued by Stevens Institute of Technology
`and the MISO Research and Development Team, the key findings of which are presented in Ms.
`Rauch’s Testimony.53
`
`While MISO recognizes that there are limitations associated with single EP Node
`aggregations, for the reasons discussed herein and in Ms. Rauch’s Testimony, MISO has
`determined that these limitations are outweighed by the benefits to overall market operations and
`reliability associated with single node aggregation.54
`MISO has revised Tariff Section 38.7 to address the Commission’s directive.
`I.
`Bidding Parameters and Distribution Factors
`
`1.
`Commission Directive
`In Order No. 2222, the Commission required MISO to establish market rules that address
`distribution factors and bidding parameters for DER aggregations.55 The Commission further
`required that MISO incorporate appropriate bidding parameters into its participation models as
`necessary to account for the physical and operational characteristics of DER aggregations.56 In
`meeting this requirement, the Commission specified that MISO must either: (1) incorporate
`appropriate bidding parameters that account for the physical and operational characteristics DER
`aggregations into its one or more new participation models for such aggregations; and/or (ii)
`adjust the bidding parameters of the existing participation models to account for the physical and
`operational characteristics of DER aggregations.57
`
`
`2.
`MISO Proposal
`
`Under MISO’s proposal, a DEAR will share many of the same offer parameters as other
`Resources, such as offer price curves and commitment parameters. A DEAR offer will contain its
`Dispatch Status for Energy, Operating Reserves and Ancillary Services, which will describe
`eligibility and desired economic treatment of the DEAR in the market dispatch algorithms.
`Additionally, a DEAR offer can describe the dispatchable range of operations consistent with its
`On-Line Commitment Status.58 Moreover, because DEAR Market Participation is currently
`limited to a single EP Node there is no need for a requirement that the DERA provide MISO with
`distribution factors as part of its bidding parameters.
` MISO has revised Tariff Sections 39.1.2, 39.2.5E, 40.2.7C, 40.2.8, and 69A.3.1 to address
`the Commission’s directive.
`
`
`
`52 Id. at 19-20.
`53 Id. at 20-22.
`54 Id. at 23.
`55 Order No. 2222 at P 225.
`56 Id. at P 227.
`57 Id.
`58 Rauch Testimony at 15.
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`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 12
`
`
`
`
`Information and Data Requirements for DER aggregations.
`J.
`1.
`Commission Directive
`
` In Order No. 2222, the Commission required MISO to establish market rules that address
`information and data requirements for DER aggregations.59 Specifically, the Commission
`required MISO to revise its Tariff to: (1) include any requirements for DER aggregators that
`establish the information and data that a DER aggregator must provide about the physical and
`operational characteristics of its aggregation; (2) require DER aggregators to provide a list of the
`individual resources in its aggregation; and (3) establish any necessary information that must be
`submitted for the individual DERs.60 The Commission also directed MISO to revise its Tariff to
`require DER aggregators to provide aggregate settlement data for a DER aggregation and to retain
`performance data for individual DERs within a DER aggregation for auditing purposes.61
`
`
`2.
`MISO Proposal
`
`Under MISO’s proposal, the DERA engages with DER Owners to understand availability
`and capabilities of potential DEAR resources. This includes collecting information on
`interconnection and retail agreement terms along with resource operating capabilities, as required
`during the DEAR registration process. After the DERA has selected DER resources to aggregate,
`and collected the needed information, the DERA would then approach MISO to register a DEAR.
`The DERA would submit information needed to perform both a Technical Review and market
`compatibility check (i.e., ensure that there is no wholesale / retail double counting). This would
`include information on items such as the DER types, sizes, locations, and operating characteristics
`necessary for MISO and the EDC to perform their reviews. The DERA will be required to attest
`that any DER requiring a valid interconnection agreement does in fact have a valid agreement in
`place.62
`Additionally, the DERA will have the obligation to submit offers to reflect their forecasted
`availability, communicate outages, and submit accurate offers into MISO’s Energy and Operating
`Reserve Markets. The DERA participating in the Resource Adequacy construct will need to meet
`applicable Planning Resource requirements, Must Offer and performance requirements, as set forth
`in the Tariff Module E-1 and Resource Adequacy Business Practices Manual.63
`MISO has revised Tariff Sections 38.1.1.k, 38.7, 61.1, Attachment TT, and Attachment
`UU to address the Commission’s directive.
`K. Metering and Telemetry Requirements for DER aggregations.
`
`
`
`1.
`Commission Directive
`
`In Order No. 2222, the Commission required MISO to revise its Tariff to establish market
`rules that address metering and telemetry hardware and software requirements necessary for DER
`aggregations to participate in MISO’s markets.64 Acknowledging the need to balance MISO’s need
`
`
`59 Order No. 2222 at P 236.
`60 Id.
`61 Id.
`62 Rauch Testimony at 40.
`63 Id.
`64 Order No. 2222 at P 262.
`
`
`
`

`

`The Honorable Kimberly D. Bose
`April 14, 2022
`Page 13
`
`for metering and telemetry data for settlement and operational purposes with not imposing
`unnecessary burdens on DER aggregators, the Commission provided MISO with flexibility to
`establish its metering and telemetry hardware and software requirements, and required that MISO
`explain in its compliance filing why such requirements are just and reasonable and do not pose an
`unnecessary and undue barrier to individual DERs joining a DER aggregation.65
`
`
`2.
`MISO Proposal
`
`In response to the Commission’s directive in Order No. 2222, MISO proposes revising its
`Tariff to establish market rules that address metering and telemetry hardware and software
`requirements necessary for DER aggregations to participate in MISO’s markets.
`Under MISO’s proposal, DEAR will be required to provide telemetry through Inter Control
`Center Protocol (“ICCP”) via private Wide Area Network (“WAN”).66 Data is required to be
`submitted every two seconds for all dispatchable DEARs, regardless of size or product. DEARs
`will be modeled as generation at the transmission/distribution interface and will require telemetry
`at the aggregation (i.e., DEAR), rather than the DER, level.67 With this requirement, the LBAs
`calculation of load will remain as it is today and will include the MW quantities of DEAR output.68
`This approach will support operational reliability by providing more accurate information on the
`supply/demand balance in every Dispatch Interval.69 This approach, using the ICCP via WAN
`methodology, will also provide more efficient market settlements, remove some potential make
`whole payments, and improve residual load calculations.70
`MISO anticipates several additional benefits related ICCP via WAN. This methodology
`matches