From: Roger Clayton Re: Notes from FERC DER Technical Conference, April Panel 4 Collection and availability of data on DER installations

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Memorandum From: Roger Clayton Re: Notes from FERC DER Technical Conference, April 11 2018 Panel 4 Collection and availability of data on DER installations Q1 Type of information? Q2 Current data & sharing? APS o Each DER site (~80,000) is separately monitored o Can have ~50% penetration on a feeder without operating difficulties o Depends upon length of feeder & DER location NERC o Need detailed steady state & stability data for modeling o Need detailed data for operating distribution system o Musk predicts 33% of peak generation to be DER penetration o DER not participating in wholesale market is not required to be telemetered but can affect BPS o Modeling of all is required IESO o DER visibility required o 20% penetration (~4000 MW) o 2017 peak load ~50,000 MW with ~7,000 MW PV & ~9,000 MW wind o PV expected to grow from ~7,000 MW to 20,000 MW in 2027 o PV is ~20% of light load presently o System operators are presently reactive with unpredictable load and variable generation o Need DER visibility, command and control specifically switching & ramp rate MISO o Data sharing between ISO, T & D not presently in place o DER must be modeled in aggregate for transmission steady state and dynamic planning studies o NERC DER Reliability & Modeling Guidelines are the minimum requirements o Netting of DER with load is to be avoided o Can start be collecting current DER data by size, location and type for development of aggregate models o German experience with 50.2 Hz over-frequency trip settings FERC DER Tech Conference 4/11/18 1

o Need for real-time behind the meter data to avoid unforeseen fast load ramp up when sun goes away o Have noted unusual voltage fluctuations due to PV Q3 DER impact on Planning & Operations o Control over before the meter DER and behind the meter DER is necessary for ramping APS o 8 MW-Hr battery deferred transmission CAPEX o Need to include DER in planning/operating scenarios (max/min DER) o Must have frequency, voltage & ramping control o Data, data, data o DER has potential benefit to BPS o IEEE 1547 was published last week o Smart DER attributes (IEEE standards & NERC guidelines) Autonomous Communication capability (3 protocols) Send/receive command/control Q4 DER Long-term projections o AMR meters at customer level gives basic planning data o How to incent customers? o Need real-time data for reliable operations o Scant data availability o Presently voluntary data collection o Behind meter DER baked into load forecast o Reactive operating regimen o Need better data projection MISO o Voluntary DER data not sufficient o Policy drivers informs future predictions APS o Trans planning 10 year process vs distribution planning 5 year process o Critical to know DER to inform trans planning NERC o DER penetration 26 GW-Hrs vs US 170 GW-hr? by 2025? Big. IESO o DER uncertainty re planning (PV & EV) FERC DER Tech Conference 4/11/18 2

o Need to know status quo to inform future predictions o Forecasts bottom up from status quo & top down from policy goals o Germany 10 year transmission planning process is open o Quasi real-time power flow simulations based on real-time data to develop heat-maps to alert operators Q7 DER aggregator data o Time scale of data communications (seconds not minutes) o Aggregation is required for ISO operations and markets IESO o Communication is important from DER to local DSO to ISO FERC DER Tech Conference 4/11/18 3

Panel 5 Incorporating DERs in Modeling, Planning & Operations Studies Q1 Best practices, T&D interaction modeling Q2 Current DER modeling Q3 More detailed DER modeling o 10 year DER predictions 7,000 MW (2017) 30,000 MW (2027) with 50,000 MW peak load (2017) o 50% DER behind the meter o Aggregated negative load behind the meter DER o Generator at BPS node for before the meter DER ComEd o DER modeled as negative load presently o No model of T&D interaction o IEEE project on smart inverter connected DER NERC o NERC DER Reliability & Modeling Guidelines are published o Individual & aggregation models are available (based upon what data?) o Steady state vs transient models Argonne Natl lab o Individual modeling of T&D DER is not feasible and co-simulation T&D studies are underway o Therefore, must aggregate by type (dispatchable & non-dispatchable), interconnection standards (IEEE 1547 vs CAISO 21?), technology o T&D interaction Combined MATLAB simulation Individual T&D coupled simulations Aggregation model American Services (MISO) o Data requirements in real-time for operations vs future for planning Case Western o Data requirements function of modeling software used o No dynamic models are available for individual or aggregate DER o Utilities must verify manufacturers models o D is three-phase unbalanced system, T is positive sequence balanced system. Tough to integrate. o Composite load model now includes DER PV_A model Inverter modeling (frequency & voltage regulation model et al see NERC DER Modeling Guideline) Etc Duke o Aggregated PV modeled as BPS node generator o Policy initiative to locate DER at best location FERC DER Tech Conference 4/11/18 4

o Transmission planning dynamic studies models Before the meter DER models available and accurate Behind the meter retail DER requires aggregate model like the CAISO PV_A model. Need more experience o Software packages (PSLF, PSS/E,?) Utility models presently exist to model before the meter DER PV_A model is now available in software packages Must add aggregated D feeders in steady state simulation to allow dynamic simulation to use PV_A models etc. Need better modeling data to utilize these models Q4 Contingency Studies & DER o Aggregated DER currently not included as a N-! contingency o Sensitivity analysis of change of magnitude of DER examined o Could be tripping of DER on frequency & voltage perturbations in dynamic simulations DUKE o Aggregated DER currently not included as a N-! contingency o Sensitivity analysis of change of magnitude of DER examined NERC o Consequential DER tripping must be simulated American Services o Sensitivity studies only ComEd o Need to simulate under frequency DER tripping o Planning models must evolve based upon IEEE 1547 performance standards selected by states (RTO/ISOs?) o Operational models should analyze loss of aggregate DER depending upon DER penetration o Need validated DER data Standardization & certification may be required Q5 Balancing requirements & DER o LSE DER survey & load forecasts used to develop 5 minute maximum ramp rate Duke o Historical DER data & load forecast to develop reserve & ramping requirements o Use CTs for ramping historically but looking at incorporating DER o Economic dispatch model down to 200 KW is being developed Case Western o Problem is using DER resources for system wide ancillary service American Services o Lack of knowledge of impact of command to aggregator system wide FERC DER Tech Conference 4/11/18 5

Panel 6 Coordination of DER Aggregations Participating in RTO/ISO Markets Q1 Distribution Utility (DSO) control over DER wholesale RTO/ISO participation o DSOs have a responsibility for safety & reliability and should have control over DER operations o I/C ~4,000 roof-top solar per month o DSO DER studies are complicated by their ability to reconfigure feeders East Kentucky Power Coop o Distribution feeders are not homogenous & DER can cause reliability problems o DSOs need definition of settlement process with aggregator o DER can connect via: Normal interconnection process Demand response o 100 kw threshold to participate in wholesale market and aggregators can make that happen o DSOs are involved in the normal I/C & DR process o Coordination is clearly needed SunRun o DSOs should only be able to intervene if there is safety or reliability issue o Possible conflict of interest with DSOs who are in the DER business o What about the role of aggregators? o Should recognize benefits of DER (generation, load modifier, ancillary service) o DER aggregators and individual have lots of data to share with DSOs and RTO/ISOs o Market solutions should be allowed to define solutions EEI o How does DER affect reliability, safety & operations for the DSO o Need for visibility of all DER & aggregator attributes o Someone (DSO?) needs to have responsibility for distribution reliability & safety Advanced Energy Economy (DER industry group) o RTO receiving aggregator DER data should be provided back to DSO o Coordination should be included in IC agreement Pacific NW Natl Lab (Jeff Taft) o Coordination between RTO/ISO and DSOs should be based upon functional roles & needs o DSO DER studies are complicated by their ability to reconfigure feeders Missouri PSC o DSO and regulator should ensure safety & reliability. o DSO should have sign-off authority FERC DER Tech Conference 4/11/18 6

Q2 Need for coordination between aggregators, DSO, TO & RTO/ISO o Three parties: RTO/ISO; TO; DSO o Visibility, communication coordination needed Missouri PSC o One size does not fit all EEI o DSO, TO, RTO/ISO & aggregator coordination absolutely necessary Sunrun o Open data access is desirable between all parties o Presently coordinating via IC studies but should evolve with DER aggregator penetration East Kentucky o PJM does UC & Dispatch of our generation resources o However, that is different from giving PJM functional control of DER on DSO feeders o Need for greater data visibility & coordination Q3 - DER aggregation in RTO/ISO markets (not addressed) Q4 Best approach to DER aggregator retail regulatory authority Missouri PSC o State needs to be the regulator o Coordination through the EDCs Q5 Grid architecture re DER aggregation Pacific NW Natl Lab o Meta-structure of coordination framework covers all parties o RTO/ISO, TO & DSO coordination not necessary pre-der o Various theoretical coordination frameworks available based on roles & responsibilities of all parties (form follows function) o Central vs de-central communication frameworks & everything in between o Current electric system is a three-tier model with two boundaries o Coordination framework depends upon roles and responsibilities of players which will define relationships & communications o May alter role of DSOs to DER/Load entities FERC Commissioner Chaterjee o Should architecture be defined by FERC East Kentucky o Need clearly defined settlement process FERC DER Tech Conference 4/11/18 7

Panel 7 Ongoing Operational Coordination Q1 Real-time data acquisition & communication technologies o TO & DSO SCADA/RTU systems are presently available o GMI is also available o Distributed Energy Resource M? (DERM) platform to translate various communication protocols Open Access Tech o SCADA telemetry is old may not be effective for real-time DER command and control o New technologies are fast, secure and cost effective re traditional methods Kristov (ex-caiso) o Electric services covering DER/load aggregation are going to be behind the meter services Miscrosoft o Digitization & scalability are new requirements at DSO level enabling DER utilization o MS can help with cloud computing etc. Open Access Tech o Application of new technologies is going to be required with increasing DER penetration ConEd & Joint Utilities o Visibility & communication from DER aggregators are not presently available & are required Q2 What processes do DSO, TO, RTO/ISO & aggregators need for coordination ConEd & Joint Utilities o Presently using phone & email & needs new real time systems o NY is developing pilot programs to explore needs Kristov o No data available to aggregators on feeder performance o DSOs need to decide on their future business model which will inform processes SCE o Business rules question o Can t define coordination processes without defining operating framework (boundary conditions, market rules, system architecture) o Federal & State jurisdictional overlap o Distribution & Transmission are attaining parity in terms of importance in operating the power system based on DER penetration Q3 Minimum set of RTO/ISO protocols, standards & market rules Kristov o DER outage and derates responsibility of aggregator need to be automated o DSOs are going to have new functional responsibilities FERC DER Tech Conference 4/11/18 8

Open Access Tech o We should look at lessons learned from OASIS e.g. electronic tagging o Jurisdiction for DER wheeling o Should not be prescriptive regarding protocols like communication standards Q4 Should DSOs be able to override RTO/ISO decisions ConEd o Yes, in emergencies, coordination needed o Yes, for safety & reliability o Closest controller has precedence Open Access Tech o Yes but must have formal rules for curtailment Kristov o Yes but need transparency & rules SCE o Yes o Function of IC scope of study process, technology application (modernization of grid) & explosion of number of elements (scale) o May need to change reliability standards to accommodate DER o Yes, must be fair & equitable o Need market rules to cover emergencies Q5 Can DER or aggregated DER improve DSO operations and reliability SCE o Yes, depending upon DER objective Microsoft o DSO support with on-site resources at data center Kristov o Multi-use applications are possible o Off-setting DSO asset reinforcement Q8 Integration of DER aggregation into EMS & DMS Open Access Tech o Integrate DER EMS into existing EMS o Topology plus DSO data will be required to model real time power flows/voltages Microsoft o Integrating learning processes into EMS o Market signal is important ConEd o Large expenditure in EMS/DMS is required o Must ensure value added to facilitate development FERC DER Tech Conference 4/11/18 9