MISO on April 7 announced it will scrap its plan to use an existing demand response participation category to get aggregators of distributed energy resources participating on a limited basis a few years ahead of its full implementation of FERC Order 2222 in 2030.  

During a DER Task Force meeting, MISO counsel Michael Kessler said the RTO decided that trying to bend the interim plan to all Order 2222 requirements as FERC recommended would be “unduly burdensome.” Kessler said MISO plans to inform FERC by July that it will abandon its DR participation idea rather than try to make it fully compliant with the rule. 

FERC accepted MISO’s second try at Order 2222 compliance Jan. 16, granting the RTO until mid-2029 to prepare before fully accepting DER aggregators into its markets in 2030. (See FERC Permits 2030 Finish Date for MISO Order 2222 Compliance.) 

The commission accepted MISO’s explanation that its underlying computer systems need work over the next four years. However, it told the RTO its plan to allow DER aggregations in its markets earlier in a two-phase rollout needed to be either deleted or revised significantly. 

MISO proposed to use a two-stage approach to Order 2222 compliance. First, it would use an existing DR resource participation category to get DER aggregations participating sooner — albeit on a limited basis — and providing energy, contingency reserves and capacity through behind-the-meter generation or controllable load. MISO would have begun registering DER aggregations under its DRR Type I model by Sept. 1, 2026, and would have allowed participation to begin by June 1, 2027. DER aggregations would have been limited to 1 MW or larger under the model. 

But in its Jan. 16 order, FERC said MISO’s proposed 1-MW size threshold is too large, as Order 2222’s minimum for participation is only 100 kW.  

The commission also said MISO’s DR placeholder doesn’t address the coordination, data requirements or means to discourage double-counting of resource contributions required under Order 2222. It decided the RTO missed the mark on using an existing participation model to eke out partial compliance. 

FERC gave MISO 180 days to either explain how the DRR Type I participation model could comply with Order 2222 or strike the first phase of participation from its compliance plan. MISO decided over the past few weeks it would not salvage that aspect for a separate filing to allow DER aggregations to provide some services by the middle of 2027. 

Kessler said MISO attempting to make its planned, interim step complaint with Order 2222 likely would require the same system changes that aren’t doable until full compliance with the rule in late 2029 through mid-2030.