MISO on Thursday said that aggregations of distributed energy resources lining up for its wholesale markets must wait until the end of the decade before gaining entry.
The announcement at a Distributed Energy Resources Task Force meeting left some stakeholders in disbelief.
The RTO said its systems won’t be ready for full FERC Order 2222 compliance until 2030. It said several software changes are needed before it can register and settle DER aggregations. It also said it faces an uphill battle to create market systems dynamic enough to “accommodate dynamic changes and communications.”
“MISO anticipates completing all improvements by 2029, enabling a 2030 launch of market functions,” the grid operator said.
The RTO said aggregator registration won’t likely become available until late 2029, with a launch of aggregator participation in the energy and ancillary services near the end of the first quarter of 2030.
DER Program Manager Kristin Swenson acknowledged that MISO “is thinking about an implementation date well into the future.”
MISO plans to file its compliance plan with FERC on April 18. Swenson said it hopes to have “pencils down” by mid-March and only make minor edits after that.
Director of Settlements Laura Rauch said full Order 2222 compliance requires MISO to shift from a “static to a dynamic paradigm.” She said its current processes for registration and market participation generally assume that resources’ output remains about the same over time.
Rauch said MISO envisions work to accommodate the registration and settlements of DER aggregations stretching into 2026. She said that work will provide a “solid foundation” for more dynamic future markets.
She also said Order 2222 will require building extensive communication channels with new parties that must be “safe, secure and confidential.”
“That’s something that factored heavily into our design here,” she said.
Stakeholders said MISO’s proposed postponement will throw sand in the gears of states and regions that want to develop robust DER participation programs.
“Obviously, 2030 is too far out,” Voltus consultant Rao Konidena said. He urged MISO to trade off some of the “bells and whistles” initially to at least get some aggregators phased into the markets before the next decade begins.
Other stakeholders also called for a “light” rollout of aggregation participation that would be less time-consuming.
But Rauch said MISO wants to avoid “putting out a market product with unintended consequences.”
“You want to do each piece well so it builds on itself and makes a cohesive whole,” she said.
“We’re looking at an eight-year implementation. How does that square with FERC telling RTOs to implement it in a reasonable time frame?” asked the Coalition of Midwest Power Producers’ Travis Stewart.
Rauch said MISO has communicated its proposed timeline with FERC staff.
Ameren’s Justin Stewart asked if MISO might complete work before its 2030 finish date.
“These are the estimates we believe we can commit to. If we go faster than that, fantastic,” Rauch responded.
MISO similarly asked for a yearslong compliance delay with FERC Order 841, claiming that it needed to embark on lengthy software improvements first. Last year, FERC twice denied MISO’s request to give it until 2025 to fully bring storage into its markets. (See MISO: No Choice but to Double Up on 841 Compliance.)
The RTO’s envisioned Order 2222 deferral is several years after its goal to have its new market platform fully operational by 2024. Staff have repeatedly touted the new platform as able to host more complex market offerings.
MISO plans to rely on its electric storage resource commitment statuses to let DER aggregations participate in the wholesale market. The RTO will leave it up to distribution companies or regulatory authorities to conduct interconnection analyses. MISO also decided that aggregations must be limited to a single pricing node and must self-commit. It will not provide output forecasts for aggregations. (See MISO Draws on Storage Model for DER Aggregations.)
In late 2021, MISO’s Richard Doying said that when staff began reaching out to distribution companies to begin collaboration on Order 2222 compliance, some had just a vague inkling of the RTO’s role in the power grid.
During a Jan. 18 workshop on MISO’s Order 2222 filing, Swenson said there was probably going to be a persistent “time horizon disconnect” over how quickly aggregators can update offers to MISO after a DER is unable to respond to dispatch instructions.
Swenson also said it’s up to distribution utilities to define the scope of their technical reviews on aggregations’ reliability impacts, which will be submitted to MISO. The RTO plans to model aggregations as generation at the transmission level and will require telemetry.
MISO’s Michael Robinson said that just like with its generation, the RTO must trust the values that distribution utilities and aggregators provide to it. He said there are tariff mechanisms in place if an entity is furnishing inaccurate numbers.
