UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`Midcontinent Independent System
`Operator, Inc.
`
`)
`)
`
`
`
`Docket No. ER22-1640-000
`
`
`
`COMMENTS AND LIMITED PROTEST
` OF ENTERGY SERVICES LLC
`
`
`INTRODUCTION
`
`On April 14, 2022, the Midcontinent Independent System Operator, Inc.
`
`
`
`
`
`I.
`
`(“MISO”) submitted its compliance filing in the above-captioned docket (“Filing”) in
`
`response to Federal Energy Regulatory Commission (“Commission”) Order No. 2222.1
`
`Pursuant to Rules 211 and 212 of the Commission’s Rules of Practice and Procedure2 and
`
`the Commission’s April 15, 2022 Notice Extending Comment Period, Entergy Services,
`
`LLC (“ESL”) acting on behalf of the Entergy Operating Companies (“EOCs”),3 submits
`
`these comments and limited protest on MISO’s Filing.
`
`As discussed in more detail herein, there are substantial portions of MISO’s Filing
`
`implementing Commission Order No. 2222 that ESL supports. A few of the more
`
`important proposed provisions that ESL supports are discussed in Section II. below.4
`
`There also are a limited number of issues where ESL protests MISO’s filing -- either
`
`
`1
`Participation of Distributed Energy Resource Aggregations in Markets Operated by
`Regional Transmission Organizations and Independent System Operators, Order No. 2222, 172
`FERC 61,247 (Sep. 17, 2020), 85 Fed. Reg. 70,143 (Nov. 4, 2020); Order No. 2222-A, 174
`FERC ¶ 61,197 (Mar. 18, 2021); Order No. 2222-B, 175 FERC ¶ 61,227 (Jun. 17, 2021).
`2
`18 C.F.R. §§ 385.211, 385.212 (2022).
`3
`The EOCs are Entergy Arkansas, LLC (“EAL”); Entergy Louisiana, LLC (“ELL”);
`Entergy Mississippi, LLC (“EML”); Entergy New Orleans, LLC (“ENOL”); and Entergy Texas,
`Inc. (“ETI”).
`4
`If an item is not discussed in these Comments and Limited Protest, ESL does not oppose
`what MISO is proposing.
`
`
`

`

`protesting a proposed provision or protesting the absence of a needed provision. See
`
`Section III. below.
`
`Important terms in MISO’s Filing are the following. An aggregator of distributed
`
`energy resources (“DERs”) is referred to as a Distributed Energy Resource Aggregator
`
`(“DERA”). The aggregation of DERs is referred to as the Distributed Energy Aggregated
`
`Resources (“DEAR”).
`
`IMPORTANT AREAS OF MISO’S FILING THAT ESL SUPPORTS
`
`II.
`A. MISO’s Requested Implementation Date Is Reasonable and Necessary to
`Ensure Reliability in MISO’s Region.
`
`MISO states that to maintain reliability in its Region, it evaluated the unique
`
`needs of stakeholders and MISO’s market systems and software in developing its Order
`
`No. 2222 compliance filing. 5 MISO requests an October 1, 2029, effective date for the
`
`Filing,6 with a DERA being able to participate in MISO’s Energy and Operating Reserve
`
`Markets on March 1, 2030. 7 MISO also states that a DERA will be able to participate in
`
`the Planning Reserve Auction (“PRA”) for the 2030-2031 Planning Year. 8
`
`ESL supports the MISO’s implementation dates. The implementation dates
`
`reflect, inter alia, the ongoing shared responsibility of MISO, its members and the
`
`Relevant Electric Retail Regulatory Authorities (“RERRAs”) to maintain reliability in the
`
`MISO Region despite numerous challenges.9 These challenges include: (i) significant
`
`
`MISO Filing, Transmittal Letter at 1.
`5
`Id.
`6
`MISO Filing, Doying Testimony at 12, lns 9-10.
`7
`Id. at 12, lns 10-12.
`8
`MISO refers to the shared responsibility as the “Reliability Imperative” see MISO Filing,
`9
`Transmittal Letter at 2.
`
`
`
`2
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`

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`shifts in the generation in the MISO Region due to the retirement of baseload resources
`
`and an increased reliance on intermittent renewable resources; (ii) increasing frequency
`
`of incidents of extreme weather; and (iii) the need to replace legacy software systems
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`relied on by MISO to operate the transmission system and administer its energy and
`
`operating reserves markets.10 In addition, many important MISO initiatives have been
`
`ongoing for years. The reasonable and efficient implementation of Order No. 2222
`
`requires that its implementation is sequenced with MISO’s ongoing initiatives. Two of
`
`the more important, ongoing initiatives are MISO’s Multiple Configuration Resource
`
`project and the software upgrade effort known as the Market Systems Enhancement
`
`project. Both are discussed below.
`
`The Multiple Configuration Resource (“MCR”) project. MISO witness Doying
`
`states that the MCR initiative has been under development for years and originally
`
`focused on the dispatch of combined cycle gas turbines (“CCGTs”) and “their ability to
`
`support reliability and create efficiencies through their lower levelized cost of electricity,
`
`higher efficiency, lower CO2 emissions, better operational flexibility, and faster
`
`response.” 11 Mr. Doying notes that over time the MCR project expanded to better model
`
`other resources and enable a more efficient use of resources.12 In describing the existing
`
`situation, Mr. Doying states that “the current design can prevent the realization of the full
`
`flexibilities and benefits of these resources and result in sub-optimal or even physically
`
`infeasible dispatch instructions.”13
`
`10
`11
`12
`13
`
`
`
`
`MISO Filing, Transmittal Letter at 2.
`MISO Filing, Doying Testimony at 10.
`Id.
`Id.
`
`3
`
`

`

`MISO performed a benefit analysis and study in 2017 on the MCR project that
`
`estimated the benefits of the project as between $14 to $34 million in annual production
`
`savings.14 MISO believes the projected benefits of the MCR project have grown
`
`significantly since 2017. Mr. Doying explains that:
`
`[t]he key variables that impact the value provided by MCRs include the
`amount of CCGT generation installed, natural gas prices, and net load
`variability, with an increase in any of these variables leading to an
`increase in the potential value of MCR. Since the original cost-benefit
`analysis conducted in 2017 installed CCGT capacity has grown by 30%,
`natural gas prices have increased 67%, and net-load variability has
`steadily increased due to a 72% increase in wind capacity, and integration
`of 1.7 GW in solar capacity. Additionally, in the next five years, an
`additional six GW of CCGT capacity is expected to come online. . . .15
`
`ESL supports the MCR project and its sequenced implementation prior to
`
`implementing Order No. 2222. The estimated MCR timeline includes upgrades for
`
`market systems, settlements, and registration and is scheduled to occur between 2025 to
`
`2027.16 The ongoing MCR project provides more immediate benefits to MISO and
`
`MISO stakeholders than implementation of Order No. 2222 and it supports maintaining
`
`and enhancing reliability in the MISO Region. While Order No. 2222 implementation
`
`also is intended to benefit MISO and MISO stakeholders and support maintaining
`
`reliability, its implementation requires (among other things) new systems and
`
`coordination procedures between MISO, electric distribution companies (“EDCs”),
`
`RERRAs, and DERAs that do not exist today and will take time to establish. It is
`
`reasonable to complete the MCR initiative prior to implementation of Order No. 2222.
`
`14
`15
`16
`
`
`
`
`
`Id.
`Id. at 11.
`See MISO Filing, Ramey Testimony at 6.
`
`4
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`

`

`The Market Systems Enhancement (“MSE”) project. As alluded to above, an
`
`equally important set of reasons supporting MISO’s proposed dates for implementing
`
`Order No. 2222 is the MSE project. MISO witness Ramey describes several key
`
`upgrades in MISO’s existing systems that are prerequisites for implementation of Order
`
`No. 2222. Mr. Ramey indicates that:
`
`the introduction of Distributed Energy Aggregated Resources (“DEARs”)
`requires MISO’s systems to accommodate resources that can shift their
`composition on a frequent basis; whereas MISO’s legacy systems were
`designed for resources that are static in their composition. As such,
`MISO’s legacy market systems, and supporting registration systems,
`cannot accommodate the flexibility required by Order No. 2222.17
`
`Mr. Ramey explains that Order No. 2222 requires flexibility to accommodate current and
`
`future technologies and that “MISO’s legacy market systems are not sufficient to
`
`accommodate larger volumes of current distributed energy resource technologies due to
`
`their age, inflexibility, and performance limitations.”18 Mr. Ramey also notes that the
`
`coordination procedures mandated by Order No. 2222 require new communications
`
`systems to a broader group of participants, including updates to MISO’s registration,
`
`enrollment, and settlement systems.19 Regarding MISO settlements specifically, Mr.
`
`Ramey states that:
`
`[s]ettlements is heavily impacted by the communication needs required to
`comply with Order No. 2222, as the processes to determine performance
`of the DEARs will create new communications needs with DERAs,
`Relevant Electric Retail Regulatory Authorities (“RERRA”), and Load
`Serving Entities (“LSE”) to ensure meter data is correctly used when
`appropriate and to perform a final check to ensure DEAR are not
`compensated twice for the same service. These communication needs
`require enabling improvements, with a focus on enhancing the existing
`
`17
`18
`19
`
`
`
`
`MISO Filing, Ramey Testimony at 2 (emphasis added).
`Id.
`Id. at 3
`
`5
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`

`

`data structure and retiring legacy workflow management tools that
`integrate MISO’s main settlement engine into the Day Ahead / Real Time
`market. Finally, the Settlement system will need to be updated to
`accommodate the settlements of heterogeneous DEARs, including
`enabling the settlement of aggregations which combine injecting DERs
`and Demand Response, and the required communications [ ] related to
`meter data or other Measurement and Verification protocols with both the
`DERAs and impacted LSEs.20
`
`Similar to Mr. Ramey’s description of the software upgrades required for
`
`settlements is his description of the needed upgrades regarding registration and
`
`enrollment of DERAs and DEARs.
`
`MISO’s Registration systems are heavily impacted by the need for
`dynamic information creation, enhanced communications, and the
`ability to handle large volumes of adjustments [associated with
`implementing Order No. 2222]. The current MISO Registration system
`was designed to manage a low number of customers participating in MISO
`markets (Registration) with simple and infrequent resource configuration
`changes (Enrollment). As MISO prepares for a market that enables
`frequent, complex configuration changes, it must redesign the Registration
`system to manage the dynamic requirements of Order No. 2222.
`Additionally, the Registration systems will need to be updated to
`communicate with DERAs, RERRAs, and Electric Distribution
`Companies (“EDCs”), both during initial Registration to validate
`interconnection requirements and ensure there is no dual compensation
`between retail and wholesale and for any subsequent modification to the
`DEAR. These communications will need to be designed to be safe and
`secure, considering both confidentiality requirements and cyber security
`protocols.21
`
`ESL supports MISO’s position that completion of the upgrades in the MSE project is “a
`
`critical prerequisite to the development of systems and software that will facilitate the
`
`participation of [DEARs] in the MISO markets.” 22
`
`
`Id. at 4 (emphasis added).
`Id. at 4-5.
`Id. at 6.
`
`20
`21
`22
`
`
`
`6
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`

`

`
`
`In sum, ESL supports MISO’s proposed implementation dates for implementing
`
`Order No. 2222. MISO’s proposed dates (i) appropriately recognize that the needed
`
`MSE software and system upgrades are prerequisites to implementation of Order No.
`
`2222, and (ii) also allow for achieving significant and more immediate benefits of
`
`important ongoing initiatives like the MCR project.
`
`B.
`
`ESL Supports MISO’s Use of a Single Elemental Pricing Node and DER
`Groups in Its Compliance Filing.
`
`MISO proposes that DEARs must participate in MISO’s Energy and Operating
`
`Reserve Markets using a single Elemental Pricing Node (“EP Node”) with self-
`
`commitment under normal conditions. 23 MISO witness Rauch explains that aggregation
`
`at a single EPNode is the broadest and most technically feasible approach to model
`
`DEARs. 24 ESL supports MISO’s determination to use single EP Nodes for DEAR
`
`participation in MISO markets.
`
`ESL also supports MISO’s determination to allow a homogenous group of DERs
`
`within a heterogeneous DEAR to be defined as a DER Group. 25 In particular,
`
`homogenous DER Groups should be useful in allowing groups of load control resources,
`
`water heater programs, and rooftop or community solar resources to participate in a
`
`DEAR.26 MISO’s proposed definition of a DER Group provides that:
`
`[f]or a group of Distributed Demand Response Resources [in a DEAR],
`each Distributed Demand Response Resource in the group must achieve
`Load reduction in the same manner, for purposes of settlement, according
`
`
`See MISO Filing, Rauch Testimony at 16; Transmittal Letter at 5.
`23
`MISO Filing, Rauch Testimony at 18. For MISO’s evaluation of multi-node
`24
`aggregations and the benefits of using a single EP Node, see Rauch Testimony at 20-23.
`25
`See MISO Filing, Transmittal Letter at 5-6; Rauch Testimony at 46-47.
`26
`See MISO Filing, Transmittal Letter at 7; Rauch Testimony at 47.
`
`
`
`7
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`

`

`to Attachment TT protocols. Energy Efficiency Resources cannot be part
`of any Distributed Energy Resource Group.27
`
`A single meter data value will be reported for DER Groups and meter data will not be
`
`required for individual DERs (devices) within a DER Group for purposes of
`
`settlements.28
`
`ESL supports MISO’s proposed definition of DER Groups. However, as
`
`discussed in Section III. below, ESL objects to a number of aspects of MISO’s Filing
`
`regarding the presence of Distributed Demand Response Resources included in a
`
`heterogeneous DEAR. For example, MISO cannot accurately settle or measure the
`
`DEAR’s performance without the presence of a separate load meter. In addition, while
`
`ESL supports the use of DER Groups for homogenous collections of Distributed Demand
`
`Response Resources that achieve load reduction in the same manner, ESL notes that it
`
`does not support measuring the performance of such Distributed Demand Response
`
`Resources using the customer baselines contained in the MISO Tariff, Attachment TT.
`
`As described in Section III. below, customer baselines allow for both payment for non-
`
`performance and non-payment for actual performance. Before and after metering should
`
`be used to measure the performance of demand response resources in a DEAR.
`
`
`
`
`
`Last, ESL notes that there are many different aspects of MISO’s Filing that are
`
`not discussed in these Comments and Limited Protest. If an item is not discussed in this
`
`document, it means either that MISO has indicated the item is subject to further
`
`development in the stakeholder process or that ESL supports or does not oppose the item.
`
`
`MISO Filing, Tariff Language, definition of Distributed Energy Resource Group.
`27
`MISO Filing, Rauch Testimony at 46. The DERA must retain the individual DER
`28
`(device) meter data for auditing purposes. Id.
`
`
`
`8
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`

`

`III. ESL’S LIMITED PROTEST
`A. MISO’s Must Specify in its Tariff that Separate Load Metering is Required
`to Accurately Settle and Measure the Performance for a DEAR that Includes
`a Distributed Demand Response Resource.
`
`MISO’s Filing states that “all DEARs must provide injection or withdrawal
`
`values, as applicable via telemetry, according to the requirements specified in Section
`
`38.2.5.e.”29 MISO Tariff § 38.2.5.e.iii. in turn, provides in relevant part that:
`
`[t]he Market Participant or MDMA shall also provide its Metered data to
`the Transmission Owner, Local Balancing Authority, ITC, or LSE or EDC
`within whose area the Load is located to the extent such information is
`needed to implement the Transmission Provider’s system operation and
`planning functions, to provide billing services to the Market Participant, to
`allow for data to be verified and agreed to by Transmission Owner, Local
`Balancing Authority, ITC, or LSE or EDC, or to permit the performance
`of calculations required by the Transmission Provider. 30
`
`The load meter data to measure performance for a DEAR that includes a Distributed
`
`Demand Response Resource is needed. MISO’s proposed tariff provisions are
`
`inadequate due to the absence of a provision specifying that separate load metering is
`
`required to accurately settle and measure the performance of a DEAR that includes a
`
`Distributed Demand Response Resource.
`
`Separate load metering of individual Distributed Demand Response Resources (or
`
`DER Groups) in a heterogenous DEAR that includes injection resources is required so
`
`that the performance of both the injection and withdrawal assets in the aggregation can be
`
`measured. The need for load metering in a heterogeneous DEAR also is required for the
`
`auditing function as set out in Order No. 2222. Finally, as discussed in the next section,
`
`separate load metering will enhance the transparency of the potentially complicated
`
`29
`30
`
`
`
`
`MISO Filing, Tab A – Redlined Tariff Language, at 38.7.C. (“Metering and Telemetry”).
`Id. at Tariff § 38.2.5.e.iii. (emphasis added; color highlighting in original).
`
`9
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`

`

`allocation of demand response costs and settlement in complying with the Net Benefits
`
`Test for demand response resources in Order No. 745. 31
`
`1.
`
`Individual Load Metering of Distributed Demand Response
`Resources in a Heterogeneous DEAR Will Add Transparency
`Regarding Compliance with the Net Benefits Test of Order No. 745.
`
`As stated by MISO witness Rauch, the Distributed Demand Response Resource
`
`portion of the meter data reported by a DERA will be settled under existing settlement
`
`rules developed for compliance with Commission Order No. 745.32 Ms. Rauch notes that
`
`for the provision of economic energy, when the LMP at the DEAR is above the Net
`
`Benefits Price Threshold (“NBPT”), the cost (market revenues) associated with the
`
`Distributed Demand Response Resource portion of the DEAR is assigned to the Reserve
`
`Zone(s) that benefited.33 When the LMP at the DEAR is below the NBPT, the cost
`
`(market revenues) is borne by the Load Serving Entity where the DEAR is located. 34
`
`ESL agrees with Ms. Rauch’s testimony. However, in addition to individual load
`
`metering being required for auditing purposes and settlement of a DEAR with a demand
`
`response resource in the aggregation, individual load metering will add needed
`
`transparency regarding compliance with Net Benefits Test (“NBT”) in Order No. 745.
`
`One only needs to contemplate the bids of a DEAR with, e.g., a 4 MW demand response
`
`resource, a 2 MW injecting resource, and a 1 MW storage resources in the aggregation.
`
`
`Demand Response Compensation in Organized Wholesale Energy Markets, Order No.
`31
`745, 134 FERC ¶ 61,187, order on reh’g and clarification, Order No. 745-A, 137 FERC ¶ 61,215
`(2011), reh’g denied, Order No. 745-B, 138 FERC ¶ 61,148 (2012), vacated sub nom. Elec.
`Power Supply Ass’n v. FERC, 753 F.3d 216 (D.C. Cir. 2014), rev’d & remanded sub nom. FERC
`v. Elec. Power Supply Ass’n, 136 S. Ct. 760 (2016).
`32
`MISO Filing, Rauch Testimony at 50.
`33
`Id.
`34
`Id.
`
`
`
`10
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`

`

`Assume that such a DEAR (in the aggregate) bids 2 MW of load reduction that is backed
`
`by 4 MWs of load reduction which, in turn, is offset by 2 MW of injections from the
`
`injecting resource and the storage resource in the aggregation. Assume further that a
`
`deviation occurs and the actual MW of demand response in the DEAR is 1 MW, not 4
`
`MWs. If the LMP at the DEAR is below the NBPT, the load reduction is not counted and
`
`the DEAR could be charged with 1 MW of net injections. The presence of load metering
`
`will increase the transparency regarding the complicated settlement and allocation of the
`
`demand response costs per Order No. 745 in the example above.
`
`As noted previously, individual metering of Distributed Demand Response
`
`Resources in a heterogenous DEAR also is required (i) so the performance of both the
`
`injection and withdrawal assets in the aggregation can be measured, and (ii) to retain
`
`performance data for individual resources in the DEAR for auditing purposes. MISO’s
`
`Filing is not just and reasonable without separate load metering for Distributed Demand
`
`Response Resources (and DER Groups of demand response resources) in a heterogenous
`
`DEAR. The Commission should direct MISO to specify in its Tariff that separate load
`
`metering is required for a heterogenous DEAR that includes a Distributed Demand
`
`Response Resource (or a DER Group of demand response resources).
`
`2.
`
`Before and After Meter Data Should Be Used to Measure the
`Performance of Distributed Demand Response Resources in a
`Homogeneous DEAR.
`
`MISO’s Filing indicates that the performance of a Distributed Demand Response
`
`Resource in a DEAR that is not supported by behind-the-meter-generation will be
`
`
`
`11
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`

`

`determined using profiled or calculated, customer consumption baselines. 35 MISO’s
`
`Filing also indicates that for Contingency Reserves provided by a DEAR, the
`
`performance of the DEAR “will be imputed through comparisons between Metered
`
`demand prior to the Contingency Reserve Deployment and Metered demand following
`
`the Contingency Reserve Deployment.”36 MISO should measure the performance of any
`
`Distributed Demand Response Resource (or a DER Group of demand response resources)
`
`in a DEAR using a before and after metering approach.
`
`The use of consumption baselines allows payment for non-performance. This
`
`occurs when, for example, the consumption baseline is 10 MW but when dispatched the
`
`demand response resource was measuring 5 MW of demand. If the resource is paid to
`
`reduce its load to 5 MWs, it will be paid for doing nothing (i.e., it will be paid for 5 MW
`
`of load reduction that did not occur due to use of the consumption baseline).
`
`On the other hand, consumption baselines also can prevent the payment for actual
`
`performance. Using the same example of a consumption baseline of 10 MW, if at the
`
`time of dispatch, the resource was measuring 15 MW and it reduced its consumption to 5
`
`MW, the resource would only be paid for 5 MWs of load reduction due to use of the
`
`consumption baseline, as opposed to the 10 MW of load reduction that took place.
`
`It is unreasonable for market participants to be subject to such costs (or avoid
`
`appropriate charges) for the inaccuracies of using consumption baselines to measure
`
`performance. In addition, ESL is unaware of how often (or whether) the consumption
`
`
`See MISO Filing, Tab A – Redlined Tariff Language, Attachment TT at §§ 3(i)(b),
`35
`3(i)(c), and 3(i)(d). See also MISO Filing, Rauch Testimony at 47-48.
`36
`MISO Filing, Tab A – Redlined Tariff Language, at Attachment TT at § 2 - Performance
`Assessment (emphasis added).
`
`
`
`
`12
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`

`

`baselines set forth in Attachment TT are updated by demand response resources.
`
`Moreover, the payment inefficiencies discussed above can occur without any intentional
`
`gaming by the owner of the demand response resource.
`
`Pragmatically, the owner or operator of a demand response resource is in the best
`
`position to know the forecasted load level at the time of bid submission in MISO’s
`
`markets and should be able to reasonably bid in demand response without the need for
`
`consumption baselines. With the availability of measuring performance with before and
`
`after meter data, there is no compelling reason to rely on consumption baselines.
`
`Finally, the measurement and performance issues associated with consumption
`
`baselines has not gone unnoticed by MISO’s Independent Market Monitor (“IMM”). In
`
`the 2020 State of the Market Report (“2020 SOM”) the IMM noted that it is important:
`
`to ensure that real-time markets produce efficient prices when [Demand
`Response] resources are deployed and to ensure that the contributions of
`these resources are measured accurately and compensated fairly. MISO
`should re-evaluate its [Demand Response Resource] measurement and
`verification provisions to address inefficiencies and eliminate gaming
`opportunities before DRR contributions rise.37
`
`The Commission should require MISO to use before and after meter data to measure the
`
`performance of a Distributed Demand Response Resource in a homogeneous DEAR.
`
`3.
`
`EDC Meters Should Be Used for Settlement of a Distributed Demand
`Response Resource in a Homogeneous DEAR.
`
`Any demand response resource in a DEAR is a retail customer of the EDC and,
`
`absent agreement by the EDC for the use of third-party metering systems for settlement,
`
`the EDC meters should be used in MISO Settlements. ESL’s recommendation is borne
`
`out of its experience with the settlement of Aggregations of Retail (demand response)
`
`
`MISO 2020 SOM Report at p. 109 (emphasis added).
`
`13
`
`37
`
`
`
`

`

`Customers (“ARCs”) in MISO. In many ARC settlements, the third-party metering
`
`systems that provided meter data to the EOCs for approval had median hourly differences
`
`of 50% or more between the ARC-submitted data and the EDC meter data. In addition,
`
`there have been numerous instances in which the ARC resource provided meter data for
`
`only one of the end use customers as opposed to all the customers within the aggregated
`
`ARC.
`
`For DEARs with Distributed Demand Response Resources neither the
`
`Commission nor MISO should countenance a DERA providing only a portion of the
`
`meter data for the demand response resources in the aggregation. Requiring the use of
`
`EDC meters for settlement for such resources will eliminate, or avoid substantially all,
`
`disputes over meter data. The Commission should require MISO to use EDC metering
`
`for settlement of any Distributed Demand Response Resources in a DEAR.
`
`4.
`
`The Commission Should Require MISO to Establish a Data
`Repository.
`
`In the stakeholder process, in discussing how to prevent double counting of a
`
`demand response resource’s performance due to dual participation in retail programs or
`
`wholesale markets, MISO considered the use of a data repository.38 The notion was that
`
`an independent data repository would be established to store the meter data for settlement
`
`of DEAR transactions. The DERA would submit the meter data for DEAR transactions
`
`and the LSE, EDC, RERRA, MISO and the DERA would all have access to review the
`
`information in the data repository. MISO did not adopt using a data repository in its
`
`
`See MISO’s March 17, 2022, FERC Order 2222 Filing Framework, Iteration 9 at page
`38
`88. Iteration 9 of the Filing Framework can be found at:
`https://cdn.misoenergy.org/20220317%20DERTF%20Item%2003c%20Compliance%20Framewo
`rk623453.pdf.
`
`
`
`14
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`

`Filing and instead chose to have the DERA report wholesale transactions to MISO with
`
`MISO making the meter data available for LSE and EDC review. MISO’s discussion of
`
`this option in its Filing is one sentence in the testimony of Ms. Rauch stating that “MISO
`
`will make submitted meter data available for LSE and EDC review, including any final
`
`review of double counting or compensation.”39 Exactly where and when this information
`
`will be made available for review is not provided.
`
`ESL recognizes that the establishing the details of a data repository for DEAR
`
`transactions would not be an insignificant undertaking. However, a data repository also
`
`would provide significant efficiencies in the settlement of DEAR transactions and reduce
`
`disputes over errors in, or conflicts regarding, meter data. The Commission should
`
`require MISO to further investigate establishing a meter data repository for DEAR
`
`transactions with a subsequent reporting obligation to the Commission on MISO’s
`
`efforts.
`
`B.
`
`Several Issues Need to be Addressed Regarding MISO’s Proposed
`Coordination Framework.
`
`MISO describes its coordination framework as including key activities and
`
`communications between MISO, DERAs, EDCs, RERRAs, TOs, LSEs, and LBAs to
`
`facilitate the interconnection, registration, operation, settlement, and modification of
`
`DEARs.40 MISO notes that (i) the coordination framework includes some activities that
`
`are outside of MISO’s purview, and (ii) some of the coordination activities discussed in
`
`the Filing may shift as appropriate entities (e.g., EDCs and RERRAs) refine their policies
`
`39
`40
`
`
`
`
`MISO Filing, Rauch Testimony at 51.
`MISO Filing, Rauch Testimony at 26.
`
`15
`
`

`

`to support DER integration. 41 Notwithstanding MISO’s caveats about the scope of the
`
`coordination framework, there are several issues that need to be addressed in MISO’s
`
`Filing regarding coordination between MISO, DERAs, EDCs, RERRAs, TOs, LSEs, and
`
`LBAs.
`
`1.
`
`MISO’s Tariff Should Impose an Obligation on a DERA to Contact
`the EDC in the Pre-registration Process and Provide Information
`about the Proposed DEAR.
`
`MISO’s Filing contains a diagram or image of the proposed coordination
`
`framework with 20 separate steps; the first 7 of which are a pre-registration process that
`
`occurs outside of the MISO processes.42 In step 5 of the pre-registration process, the
`
`DERA provides the EDC with information on the proposed aggregation. While Step 5 is
`
`a pre-registration process, there should be an obligation in the MISO Tariff that the
`
`DERA will contact the EDC and provide it with some preliminary information on the
`
`proposed DEAR. In ESL’s experience, the absence of such a requirement in MISO’s
`
`ARC process (i.e., the absence of a requirement for an ARC applicant to provide the EDC
`
`with preliminary information on the proposed ARC) causes issues that could be avoided
`
`if the MISO Tariff contained a pre-registration obligation on the ARC applicant to
`
`provide the EDC with information about the proposed ARC.
`
`Furthermore, the fact that the obligation for a DERA to contact the EDC is part of
`
`the pre-registration process does not mean it is unreasonable to include the obligation in
`
`the MISO Tariff. Indeed, in discussing the EDC portion of the DEAR technical review,
`
`MISO witness Rauch indicates that:
`
`41
`42
`
`
`
`
`
`Id.
`See MISO Filing, Transmittal Letter at 15; and Rauch Testimony at 27.
`
`16
`
`

`

`[a]lthough the EDC portion of the DEAR Technical Review is outside of
`MISO’s review process, MISO has established criteria to coordinate
`through the LBA with the EDC to ensure the safety and reliability of the
`distribution system when dispatching DEARs. 43
`
`The Commission should require MISO to provide an obligation in the MISO Tariff for a
`
`DERA to contact the EDC in the pre-registration process and provide it with preliminary
`
`information on the proposed DEAR.
`
`2.
`
`MISO’s Tariff Should Impose an Obligation on DERAs to Respond to
`EDC Questions on the Proposed DEAR in the EDC’s Technical
`Review.
`
`MISO witness Rauch explains that “[w]hile the DERA is expected to have a
`
`limited role in the DEAR Technical Review, it may have to respond to information
`
`requests from EDCs on its DEAR proposal.”44 Proposed MISO Tariff § 38.7 does not
`
`contain an obligation for a DERA to respond to EDC questions in the EDC’s Technical
`
`Review of the DEAR. The Commission should require MISO to include such an
`
`obligation in its Tariff.
`
`3.
`
`The MISO’s Tariff Should Include Provisions Regarding an EDC’s
`Ability to Override MISO’s Dispatch of a DER Resource When
`Needed to Maintain Reliable and Safe Operation of the Distribution
`System.
`
`In discussing the proposed coordination framework and operational
`
`communication, MISO witness Rauch states the following:
`
`The DERA will be responsible for providing the EDC with the individual
`DER outputs planned to meet the MISO DERA dispatch target.
`Alternatively, the DERA may register an internet location for the EDC to
`be copied on notifications from MISO. The EDC will be responsible for
`determining if overrides are needed and for contacting either the DERA or
`DER Owner. The DERA will then be responsible for using a Real Time
`
`43
`44
`
`
`
`
`MISO Filing, Rauch Testimony at 38-39.
`Id. at 40.
`
`17
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`

`

`Offer override to update its offer limits inside of the operating hour and
`update its Real Time Offer for future hours, as necessary.45
`
`There are a few things to note about this testimony. First, the system needed for a DERA
`
`to provide an EDC “with individual DER outputs planned to meet the MISO DERA
`
`dispatch target” does not exis