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DOE's Office of Energy, Electricity Advisory Committee (EAC) FERC Order 2222 Recommendations

image credit: US DOE
Richard Brooks's picture
Co-Founder and Lead Software Engineer Reliable Energy Analytics LLC

Dick Brooks is the inventor of patent 11,374,961: METHODS FOR VERIFICATION OF SOFTWARE OBJECT AUTHENTICITY AND INTEGRITY and the Software Assurance Guardian™ (SAG ™) Point Man™ (SAG-PM™) software...

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  • Apr 25, 2021

A DOE EAC meeting was held on 4/22 where draft recommendations regarding FERC Order 2222 were presented to the DOE. Here are my key take-ways from the "DRAFT" recommendations contained in this  document:

One of the most critical requirements relates to the types of operational coordination needed across the transmission, distribution, and customer domains to enable DER aggregation for wholesale market participation while preserving system safety, reliability, and resilience. [RJB] Practices to ensure reliability and resilience are being challenged by higher penetration rates of Variable Energy Resources, and Distributed Energy Resources in general, and difficulties in load forecasting.

a much broader range of requirements that the order raises related to technology, operations, market design, regulation, and planning (see Appendix for full listing). Informed by a deeper appreciation of these myriad requirements following the Order 2222 panels in which EAC members participated, the Committee collectively recognized that prospective actions to comply with Order 2222 present significant complexities for successful implementation.

Additionally, while the most immediate focus is on compliance filing development, there is also a need for action to guide each region’s implementation efforts.7

The EAC believes that DOE should take immediate actions to help stakeholders meet the urgent challenge of complying with Order 2222. DOE has already done significant work that can support regional efforts to address the complex requirements that Order 2222 raises. For example, the Office of Electricity’s (OE) extensive work on smart grid development8 can guide stakeholder development and implementation of systems and standards to enable two-way power flow, DER dispatch, and load and voltage management, and cybersecurity measures that are harmonized across the transmission and distribution systems.

Additionally, DOE’s work on grid architecture9,10,11 can help identify pathways for mitigating issues related to transmission-distribution-customer operational coordination processes, including how to allocate roles and responsibilities between various system actors based on a jurisdiction’s policy objectives, and define information and data exchange requirements.[RJB] ISO New England emphasized this need during the NIST SGIP initiatives in 2009.

DOE is uniquely positioned to take steps to ensure timely and successful outcomes of Order 2222.[RJB] I agree. DOE's Grid Modernization initiatives are key to the success of Order 2222, especially with regard to standard definitions and characterizations of "essential grid services" that a DER can offer into wholesale capacity markets.

Regions will need to assess the need to refine or create new tools, technologies, and protocols critical to the implementation of the order. These include a myriad of processes and software and hardware tools, including communication protocols for the various types of DERs on the system, DER day-ahead forecasting, analytical approaches to model and analyze DER aggregation system impacts, system and DER visibility requirements, and resource planning that supports greater coordination between distribution and bulk system needs

Recommendation 4: Establish ongoing policy collaboration structures to enable federal agency coordination and collaboration with industry, state, and local stakeholders.[RJB] the EAC "DRAFT" recommendations include a broad array of industry stakeholders, however one, very important Energy Standards Entity that was not listed is the "North American Energy Standards Board (NAESB)". NAESB performs an important role in developing wholesale market standards for FERC consideration and is perfectly positioned to address the wholesale/retail divide given their focus on both "Wholesale" (WEQ) and Retail (REQ) segments. NAESB has an initiative underway to develop data dictionary standards to support Order 2222 implementation, based on the specific use cases introduced by Order 2222, i.e. DERA-> ISO/RTO interactions.

As part of these efforts, DOE should support stakeholders in developing a common set of use cases that illuminate the types of impacts introduced by Order 2222 that need to be addressed. These use cases should capture a wide range of potential considerations stemming from the order, including but not limited to aggregation characteristics (e.g., resource type mix, size, grid services provided), distribution utility requirements for studying aggregation impacts to the distribution system, and information/data exchange between key system actors.[RJB] The next NAESB meeting on the DER data dictionary standards development work for FERC Order 2222 has an agenda item to discuss additional FERC Order 2222 use cases for data element standardization development.

[RJB] I fully support these DOE EAC recommendations, and look forward to working with DOE, and the entire electric industry (wholesale and retail) on standards to support FERC Order 2222.






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