Most commentators, including MISO states, want FERC to reject the Midcontinent ISO (MISO) proposal to implement FERC Order 2222— and allow distributed energy resources to participate in the wholesale market — by 2030. Beyond the implementation date, most comments asked FERC to reject MISO’s single node proposal in favor of a multi-nodal aggregation model. Only some distribution utilities filed in favor of MISO’s 2030 implementation date.
Since FERC has started issuing decisions on CAISO and NYISO proposals, there are important lessons to be learned for MISO and SPP.
Taking the cue from FERC’s decision on NYISO’s proposal, FERC is encouraging the distribution utilities to look at the incremental impacts of DER interconnections. It is unknown until MISO files responses to the comments received if it decides to go against its states and FERC on this Order 2222 proposal.
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Feedback on the MISO proposal
The general feedback on MISO’s Order 2222 proposal has been robust compared to SPP’s.
Eighteen comments were filed compared to the eight in SPPs, with the majority asking FERC to reject MISO’s long implementation date. Ten out of eighteen (55%) organizations filed comments supportive of DER providers – Advanced Energy Management Alliance (AEMA), Illinois Commerce Commission, Voltus, Michigan PSC, Entegrity Energy Partners, Solar Energy Industries Association (SEIA), Advanced Energy Economy (AEE), Public Interest Orgs, Organization of MISO States, Missouri PSC, and the Indiana Utility Regulatory Commission.
Environmental Law and Policy Center, Carmel Green Initiative, Inc., Citizens Action Coalition of Indiana, Energy Matters Community Coalition, Inc., Natural Resources Defense Council, Sierra Club, Solarize Indiana, Inc., Solar United Neighbors, Sustainable FERC Project, and Union of Concerned Scientists comprised the Public Interest Orgs.
Seven out of eighteen (38%) filed comments supporting MISO’s 2030 implementation date – Xcel Energy, Entergy, Ameren, Detroit Edison, MISO Transmission Owners, Consumers Energy, and Alliant Energy. WPPI Energy raised an issue about transmission charges that FERC could say are outside the scope of this 2222 docket.
Background: What is FERC Order 2222, and what does it mean for renewable energy?
Pushing back against MISO
Going into the FERC docket on MISO’s proposal, it was a given that industry alliances and associations such as AEMA, SEIA, AEE, and public interest organizations would push hard on MISO to implement the Distributed Energy Aggregated Resource (DEAR) model earlier than 2030.
But what was surprising to most was the number of comments filed individually and as an organization by state commissions inside the MISO footprint favoring a DEAR implementation in parallel with MISO’s proposed Multiple Configuration Resources (MCR) market upgrade.
Michigan PSC’s statement sums up the sentiment across most stakeholders in this “push MISO hard” camp: “While there are certainly obstacles to rapid implementation, MISO has not demonstrated that these obstacles justify an implementation date that will prevent distributed energy resource aggregators from participating in MISO’s wholesale market until the next decade.”
The Organization of MISO States (OMS) questioned how MISO arrived at its final prioritization (of sequencing MCR in advance of DEAR) and suggested that MISO implements DEAR in parallel with MCR.
This sentence from OMS comments sums up the general feeling among most stakeholders: “MISO did not propose their 2030 timeline until February 2022, which caught many parties off-guard and may have impacted the positions OMS took earlier in the stakeholder process.”
Another striking feature of OMS comments is that MISO’s proposed single node aggregation model did not go well with them in addition to public interest organizations and AEMA, SEIA, and AEE. SEIA and AEE comments included an example of how single nodal aggregation is a barrier in Michigan.
MISO control room. Credit: https://www.misoenergy.org/about/Utilities side with MISOInvestor-owned utilities (IOUs) from Minnesota, Wisconsin, Michigan, Missouri, and Entergy from MISO’s South region all favored MISO’s proposed 2030 implementation date for the DEAR model.
Speaking for its Minnesota utility, Northern States Power (NSP), Xcel Energy suggested to FERC that a pause might be warranted in interconnecting DERs because their distribution systems are not ready.
Entergy’s protest raised several operational coordination details. For instance, Entergy wants the MISO tariff to impose an obligation on the aggregator to contact the utility during the “pre-registration” process, entirely missing the voluntary nature of MISO’s pre-registration process.
FERC is unlikely to side with a distribution utility like Entergy because none of the technical aspects raised provide any transparency in how the utility would conduct its safety and reliability checks.
FERC decisions in California and New York could impact MISOFERC has started weighing on ISO Order 2222 proposals. The agency sent decisions on both California ISO and New York ISO proposals on June 17.
FERC had much to say about interconnections in NYISO’s proposal to implement 2222. FERC asked NYISO to clarify that DER interconnections do not fall under Small Generator Interconnection Procedures, which is relevant for MISO because MISO’s proposal leans heavily on generator interconnection procedures and concepts for DER interconnections.
FERC also took a hard stance on NYISO regarding heterogenous aggregations (aggregations with multiple DER technologies). FERC directed NYISO to file a compliance filing by August 17 to ensure heterogenous aggregations participation in the ancillary services markets.
The most important takeaway for distribution utilities from FERC’s decision on NYISO’s filing is that FERC asked NYISO to revise its tariff and that any DU review is limited to incremental impact from a resource’s participation and that has not been considered previously by the DU in its interconnection process.
This last point saves much interconnection study time and helps DER providers bring DERs to the wholesale markets sooner than later.
ConclusionMISO has three weeks from the June 6th date to respond to comments.
It remains to be seen if MISO is going to request an extension to respond to FERC as PJM did. FERC could send a data request to both MISO and SPP simultaneously. FERC could also initiate the technical conference that Voltus and others requested back in February.
