MISO is gearing up to draft FERC-mandated rules before it welcomes potentially thousands of distributed energy resource aggregations into its markets.

Last week’s preparation and discussion was in response to FERC’s Order 2222, which directs RTOs and ISOs to allow DER aggregators to compete in their markets. (See FERC Opens RTO Markets to DER Aggregation.)

During a teleconference Thursday, MISO’s Market Subcommittee voted to create a stakeholder task force to handle the work. The Steering Committee is expected to approve the task force’s creation Monday.

“It was 2016 when FERC issued its first DER aggregation Notice of Proposed Rulemaking,” MISO DER Program Director Kristin Swenson told stakeholders. “We’ve been waiting for this a long time.”

Swenson said MISO must create a “coordination framework” for compliance purposes that facilitates communication among itself, regulatory authorities, distribution utilities and DER aggregations. She said the RTO’s many state jurisdictions means the grid operator faces a challenge in creating multiple operating procedures.

“MISO has a tall order in front of us. … We need to learn how to work with each other in a new way to facilitate all of these new resources on the distribution system,” she said. The grid operator will create a new market participation model for DER aggregators, she said.

“Some folks said that this is the first time they’ve seen a FERC order leading the technology development,” Swenson said. “It’s a pretty exciting order.”

Swenson said staff will focus on how MISO can avoid double-counting DERs in metering and telemetry. “How do we avoid double-counting a DER in both the retail and wholesale markets? To be determined,” she joked.

Earlier this year, Swenson said MISO views visibility into DERs as its first challenge.

“We need to obviously understand shifts in pattern [and] in load. If a lot of rooftop solar is installed, for instance, that can affect our load patterns,” she said during the Reliability Subcommittee’s meeting in April. “We’re mindful that we need to better match some of our processes to changes in the industry.”

Swenson said staff continue to look for solutions to MISO’s “aggregation balance problem,” when the market system, burdened with several thousand points of generation, cannot solve. The system could have trouble locating aggregated DERs’ precise location to alleviate reliability issues.

MISO has until July 2021 to submit a compliance filing at FERC. Swenson said she hopes it’s “pencils down” in June to give time for legal staff to review the proposed compliance.

Swenson said the RTO is planning to hold multiple workshops on how it designs its Order 2222 compliance. The grid operator is also supportive of stakeholders and its state regulators’ decision to form a task force to guide compliance, she said.

The Organization of MISO States (OMS) pressed for a state regulator-led task force as soon as possible during a conference call of the RTO’s Steering Committee on Nov. 3.

“OMS is interested in digging in as soon as possible,” Executive Director Marcus Hawkins said.

Some Steering Committee members bristled that OMS would propose a MISO task force with handpicked leadership in mind. Hawkins said he was only giving the stakeholder community a heads-up that multiple OMS members are interested in helming a new task force. He said the usual stakeholder vote on task force chairs would naturally take place.

“OMS is just being transparent with the fact that it will put people forward,” Hawkins explained.

Swenson said coordination with OMS will be pivotal to MISO’s compliance filing.

“We know this is a state-jurisdictional system; so, much of how this order plays out will be determined by the [relevant electric retail regulatory authorities],” she said. “Understanding what the plans are of each state is critically important to us.”

Stakeholders asked during the Market Subcommittee meeting Thursday whether FERC’s rules always necessitate an RTO task force.

“It depends on the complexity of the issue. And this order touches on several areas,” subcommittee Chair Megan Wisersky said.