DR Aggregator Facts & FAQ

State of Michigan Load Modifying Resource (LMR) Registration FAQ

Background

• On September 29, 2009, the Commission issued an Order in Case No. U-16020 in which it opened an investigation into participation of retail customers in regional transmission operator wholesale markets.  On December 2, 2010, the Commission determined that retail customers and aggregators of retail customers (ARC) shall not participate in these markets and after consideration of FERC Order 745 appeal, the ban was maintained, and the docket was ultimately closed on March 29, 2016.
• On September 15, 2017, the Commission issued an Order in Case No. U-18369 which, pursuant to Staff’s request for consideration, the Commission determined that an alternative electric supplier (AES), as the load serving entity (LSE), may offer demand response (DR) capacity from its own customers into the market but aggregation by third party ARCs was outside of the scope.  The aggregation ban remained in effect.
• On November 21, 2018, the Commission issued an Order in Case No. U-18197 that stated an AES may use DR capacity resources from another AES and commenced a collaborative.
• The Commission’s August 8, 2019, Order in Case No. U-20348 maintained the ban for bundled retail load but lifted the ban on third party ARC aggregation for AES customers.
• On December 21, 2022, the Commission’s Order in Case No. U-21099 lifted the ban on retail electric customers of Commission-jurisdictional utilities (non-choice customers), limited to 1 MW of enrolled load for commercial & industrial customers.

Frequently Asked Questions

This FAQ document has been created to provide additional clarity to ARCs, local balancing authorities, and the public for adherence to the requirements set forth in the Commission’s December 21, 2022, Order in U-21099.

Q1. What information will be evaluated by a Load Serving Entity (LSE) or Local Balancing Authority (LBA) per MISO Load Modifying Resource (LMR) Requirements?

A1. The LBA and LSE will verify the following:

• LBA Name
• LSE Name
• Relevant Electric Retail Regulatory Authority (RERRA) Name
• CPNODE Name
• End Use customer account number
• Meter identification numbers
• Maximum level of participation (MWs)
• Address of the assets in the ARC registration

Source: MISO Resource Adequacy Business Practice Manual – BPM 11 Business Practices Manuals (misoenergy.org)

Q2. What is the minimum capability for an LMR registration?

A2. A corporate entity must demonstrate the required capability of 1 MW by:

A single customer must show a peak usage for any hour in the preceding three years of at least 1 MW.

Multiple sites for a single corporate entity must meet an aggregated minimum peak usage for any hour in the preceding three years of at least 1 MW. The Market Participant (MP) is required to provide documentation of a corporate relationship. This documentation should include an affidavit from the customer with corporate contact information if necessary or publicly available data showing proof of a corporate relationship, such as a company website or valid media reports. Additionally, if multiple sites are used in the aggregation, the total aggregation for each individual corporate entity must reach a 1 MW threshold DR capability in at least one season in the Planning Year.

Note: Per above, the MP has the burden of proof to demonstrate this corporate relationship. If such proof is not provided, standard practice will be to reject the MISO registration.

Source: Michigan Public Service Commission Orders in U-20348 (12/2022 and 2/2023)

Q3. What methodology will be utilized when validating capability of accounts registered as an LMR?

A3. The asset’s load should be calculated as the average load of the assets up to the last three years seasonal MISO system peak hours. There may be variance between seasons for 3-year average MISO peaks. The MP is required to provide the proposed capability of each individual site within a registration. The proposed capability will then be compared to the 3-year average load at the MISO peaks for the registration season for each account. The proposed capability must be less than or equal to the 3-year average of the MISO peaks or the entire registration for that season will not be verified. If multiple sites are used in the aggregation, the total aggregation for each individual corporate entity must reach a 1 MW threshold DR capability in at least one season in the Planning Year. Additionally, the total proposed capability will be compared to the total 3-year average load at the MISO peaks for the registration. The proposed capability must be less than or equal to the 3-year average load at the MISO peaks or the entire registration for that season will not be verified.

Source: MISO Resource Adequacy Business Practice Manual – BPM 11 Business Practices Manuals (misoenergy.org)

Q4. What information is required for the Electric Distribution Company (EDC), LBA and/or LSE to complete the reviews within the 10-day review period?

A4. The EDC, LBA and/or LSE should receive the following information for all new registrations. This should be received by the EDC, LBA and/or LSE on the same day MISO sends the file notifying all parties of a new registration. The acceptance of any exceptions to the 3-year MISO peak average is at the discretion of the EDC, LBA and/or LSE.

1. Email from MISO containing excel file with registration and account information.
2. Individual account capability information – this can be sent by MISO or the MP. If sent by the MP, it should clearly reference the appropriate registrations.
3. Any relevant information outside of the required MISO registration information that impacts the EDC, LBA and/or LSE review of registrations, including details for occurrences when the MP believes there should be an exception made to the 3-year MISO peak average or other special circumstances.

Note: the standard MISO registration requirements will not include a column to input corporate relationship information. Regardless, the MP will need to communicate this information to the EDC, LBA and/or LSE. Failure to do so will result in rejection of the registration.

Q5. Is the registration approved if the total capability for a Season is greater than the total capability calculated by the reviewing party (EDC, LBA or LSE)?

A5. No. If the total proposed capability is greater than the total 3-year average load at MISO peak, the registration will be marked as “Not Validated” for that season.

Q6. Is the registration approved if a single customer within a registration has proposed capability that is greater than the 3-year average load at the MISO coincident peak?

A6. No. The MP must provide the proposed capability for each account in each season. The proposed capability for each account by season is compared to the calculated account capability for each account by season. If the proposed capability for any account is greater than the EDC/LBA/LSE calculated capability for the same account, the registration will be marked as “Not Validated” for that season.

Q7. Can corporate entities be registered in two different LBAs to meet the minimum 1 MW requirement?

A7. No. A corporate entity must meet the 1 MW threshold within a single LBA territory to protect customer data and privacy especially in situations where the LBA is subject to Michigan Public Service Commission (MPSC) Customer Protection and Data Privacy Rules. This restriction remains in place at least until technological and process improvements can be made to securely share customer data.

Q8. Can accounts be registered having multiple LSEs or CPNODEs in a single registration?

A8. No. For an LMR registration, it is required that aggregation be within the same LSE and Load Zone CPNODE.

Source: MISO Aggregator FAQ (misoenergy.org) page 4

Q9. Can accounts be registered having multiple EDCs in a single registration?

A9. No. For an LMR registration, it is required that aggregation be within the same EDC.

Q10. Can accounts and registrations be resubmitted if they are initially determined to not meet all validation requirements?

A10. Yes. The MP can re-submit registrations and accounts once items that could not be validated are updated and re-submitted to MISO. The 10-day review window starts over upon receipt of new registration by EDC, LBA and LSE.

Q11. Can MPs reach out to LBAs for a preliminary verification of proposed account information and 3-year peak usage data prior to registration submission to MISO.

A11. DTE Electric Company and Consumers Energy Company completed these reviews in 2023 for PY 2024-25, but these requests should be made well in advance as these reviews do take significant time. Preliminary review and 3-year usage data requests ideally to be received in October and completed in November of each year.

Q12. What is required to complete preliminary verification for each account?

A12. A valid Letter of Authorization is required to be submitted to the utility before the utility can release customer information.

Q13. Who is the RERRA for accounts registered in Michigan?

A13. The MPSC is the RERRA for all accounts unless a customer is part of a municipality or cooperative.

Q14. Who is responsible for providing proof of a corporate relationship between customers in an aggregation?

A14. It is the responsibility of the MP to provide documentation of a corporate relationship between customers.

Q15. Can customers be registered in multiple programs within the same season?

A15. No. This limitation is intended to prevent double counting of resources.