MISO is free to keep working toward its 2030 goal of fully incorporating aggregators of distributed energy resources into its markets without an interim participation option, FERC ruled in an order on rehearing.
The commission’s July 10 order denied aggregator Voltus’ request to compel MISO to reinstate a temporary role for aggregators in its markets while it works on full FERC Order 2222 compliance (ER22-1640).
MISO nixed the provisional step from its first compliance proposal in the spring after the commission said it didn’t fit within the requirements of Order 2222. The RTO planned 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. (See MISO Discards Interim Participation Option from Order 2222 Plan.)
FERC disagreed with Voltus’ contention that it got it wrong when refusing the partial participation. The commission said its history of accepting interim models while grid operators work on full compliance with orders and directives on a longer timeline didn’t apply in this case because MISO’s pro tem demand response plan contained elements that didn’t square with Order 2222.
FERC said its precedent of approving an interim plan for electric storage resources in MISO markets before the RTO complied with Order 841 was fundamentally different because that case dealt with a Section 206 complaint under the Federal Power Act, not Order 841 itself. Voltus cited Indianapolis Power and Light’s (now AES Indiana) 2017 complaint over MISO’s treatment of the utility’s Harding Street Battery Energy Storage System when arguing for rehearing. (See MISO Ordered to Change Storage Rules Following IPL Complaint.)
FERC said it continues to find MISO’s provisional demand response model lacking, namely its failure to meet Order 2222’s 100-kW minimum size requirement for aggregations. The commission also said it was unpersuaded by Voltus’ claim that it ignored the benefits of a timelier rollout of at least some Order 2222 directives. FERC said it wouldn’t debate a piecemeal implementation further.
FERC backed MISO’s 2030 effective date for its comprehensive distributed aggregation model and said it was “timely,” irrespective of a partial rollout. The commission once again underscored MISO’s reasoning that its underlying computer systems need work over the next four years before they can support aggregations.
“MISO stated that the foundational enhancements to its settlement systems are expected to be completed in the middle of 2028,” FERC said. It disagreed with Voltus that MISO didn’t expound on which specific settlement upgrades would be necessary, and said MISO provided detailed timelines that outlined delays and additional work.
