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FERC should reject MISO’s Order 2222 compliance filing

No other ISO has proposed a 2030 implementation date and the reasons for a longer lead time are not unique to MISO.

FERC should not get carried away by MISO’s multiple stakeholder iterations to put together the Order 2222 compliance proposal. No other ISO has proposed a 2030 implementation date and the reasons for a longer lead time are not unique to MISO. Even though FERC explicitly mandated that DERs not enter the generator interconnection queue, MISO’s proposal looks like the queue because of an increased role for distribution utilities.

In addition to the long implementation date and $60,000 interconnection study deposit requirements, MISO’s proposal does not clarify retail and wholesale market participation for net-metered DERs. MISO’s proposal does not move the needle for multi-nodal aggregation as well.

Hence FERC should reject MISO’s filing without prejudice.

The 2030 implementation date is unbearable

MISO chose to stage a market improvement for natural gas combined cycle units in front of the market upgrades needed for aggregated DERs to comply with Order 2222. This upgrade is the primary reason for the 2030 implementation date.

When MISO discussed metering and telemetry requirements for DERs leading up to the February task force meeting, MISO did not specify it has a problem scaling communication requirements for the distribution utilities. Aggregators and other DER providers expected MISO, like other ISOs, to propose an implementation date in the 2024-2026 timeframe because of the complexity of addressing some of the 2222 requirements, including communication infrastructure.

But MISO exceeded stakeholder expectations by proposing a 2030 date. Another reason MISO cites is the static nature of generation resources versus the dynamic nature of DER aggregations in the future. MISO asserts that future resource aggregations could be homogeneous or heterogenous, so MISO needs a long lead time to prepare its market systems. But this problem is not unique to MISO, nor is this problem new at MISO. MISO currently has demand side resources, load modifying resources, and behind the meter generation, all participating from the transmission and distribution interface, which change with quarterly commercial model updates. Hence MISO is not new to changes in the market registration process.

DER aggregators and providers now have to find ways to aggregate under existing market models such as Electric Storage Resource, Demand Response Resource, and other demand side models. None of which afford the benefit that 2222 offers, aggregating different DER technologies under one model. The aggregators must choose which model to participate in and when quarterly. FERC must challenge MISO for a shorter implementation date.

The DER interconnection requirements are similar to generators

FERC Order 2222 explicitly states that DERs do not have to go through the generator interconnection queue, but MISO proposes that DERs jump through hoops that look like the MISO interconnection queue study phases. The “pre-registration” process looks like the “pre-queue,” the $60,000 study deposit is similar to the queue study deposit, and the Affected Systems Study all make DER interconnections look like the MISO queue.

MISO insists distribution utilities are better positioned to interconnect DERs. No one argues with that. But MISO makes the distribution utilities the first responders to DER’s market participation. This requirement is not what FERC meant by ISO coordinating with the distribution utilities.

Pre-registration is recommended by MISO for distribution utilities interconnecting DERs but is not mandated. This recommended step looks like pre-queue education in the MISO queue process.

Additionally, MISO proposes that the utilities collect $60,000 study deposits from DER providers and quarterly report the studies received for MISO analysis, similar to the generator queue.

Affected systems studies are the primary reason for multiple delays in generator interconnection queue cycles at MISO and SPP. When an interconnection customer at MISO impacts SPP’s transmission system, the interconnection study results bounce back and forth between MISO and SPP interconnection engineers. Hence the current delay in the generator queue. If DERs must follow the same rules, one can expect multiple-year delays for DERs like generators.

MISO proposes that DERs interconnecting at one distribution utility would impact another distribution system. But DERs are not generators, and it is unlikely that most aggregated DERs would be “affecting” anyone’s distribution system. FERC must reject MISO’s compliance proposal and ask for a cleaner interconnection ruleset for DERs. None of the ISOs have proposed an affected systems study in their compliance proposal.

Too many holes in the double counting and multi-nodal aggregation

The third reason for FERC to reject MISO’s filing is much simpler compared to both the 2030 date and interconnection rules. It is simple because MISO didn’t address the double-counting requirements.

Double compensation occurs when a resource is getting paid for providing a retail service like demand response and paid a wholesale price for participating in energy markets for providing that same service – demand reduction. In retail states like Illinois at MISO, the wholesale transaction from a demand response resource is settled at wholesale price, and the Aggregator of Retail Customer attests that resource is not getting paid on the utility retail tariff rate. But MISO did not engage stakeholders on these retail versus wholesale tariffs for net energy metered solar with behind-the-meter storage, a popular DER aggregation.

At a recent workshop, MISO asked the state PUCs, and Electric Distribution Companies who should take the lead on the double-counting issue, and both states and the utilities asked MISO to put together an initial proposal, which MISO didn’t in the compliance filing.

In addition to the lack of detail on double-counting, MISO didn’t address the multi-nodal issue.

Distributed Energy Aggregated Resource (DEAR) participation model and DER groups are the only good thing

With three major holes in MISO’s compliance proposal, are there any good things that came out of MISO’s stakeholder discussions?

MISO has a market participation model that accommodates both injection (storage) and curtailment (demand response), unlike SPP, but we must wait until 2030. MISO’s storage model is available starting June 2022.

MISO also has a DER group definition that works for all homogeneous technologies like water heaters, solar, and electric vehicle charging infrastructure. Each DER group must have similar measurement and verification requirements, ensuring metering and telemetry are done in aggregate at the group level. None of the other ISOs have defined a group. MISO didn’t tinker with multiple existing models like ISO-NE.


Last year, MISO asked for an extension to file its compliance plans, joining PJM, ISO-NE, and SPP. But when FERC looks at MISO’s compliance plan and compares it against the other three ISOs that asked for an extension, MISO probably lands in the bottom tier due to the reasons mentioned earlier. FERC should reject MISO’s proposal and ask MISO to develop a plan implemented in 2024-2026 and keep interconnection requirements clean and simple.

MISO FERC filing is Docket # ER22-1640 and comments are due by 5 PM ET on June 6th, 2022.

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