Multiple stakeholder groups, including state regulators, protested MISO’s FERC Order 2222 compliance filing on Monday, with many expressing indignation with the RTO’s request to delay implementation until nearly 2030 (ER22-1640).

MISO filed its proposal April 14, with the commission granting its request to extend the standard 21-day comment period until June 6. In a letter accompanying the proposed tariff changes, MISO said its proposed Oct. 1, 2029, effective date is necessary because it will take “several years of technology development to enable DERA [distributed energy resource aggregation] participation in wholesale markets.”

Approved in September 2020, Order 2222 directed all FERC-jurisdictional RTOs and ISOs to revise their tariffs to allow DERAs to provide any services they are technically capable of in their wholesale markets. (See FERC Opens RTO Markets to DER Aggregation.)

The commission had set a compliance filing deadline of nine months after the order’s publication in the Federal Register (about June 2021), but several RTOs quickly requested more time, with PJM and ISO-NE, for example, filing on Feb. 2 (2/2/22). Over that time, officials repeatedly told stakeholders how complex and time consuming the work was. (See “Order 2222 Compliance Work ‘Highly Complex,’” SPP Markets and Operations Policy Committee Briefs: April 11-12, 2022.)

FERC gave RTOs and ISOs flexibility in proposing a deadline for implementation. MISO’s is the longest among the grid operators. It proposes making registration available beginning Oct. 1, 2029, with participation in energy and ancillary service markets offered by March 1, 2030. The RTO told FERC that it first needs to complete its market systems enhancements (MSE) project — a long-in-the-works replacement of its market platform expected by the end of 2024 — before it has the technological capability to comply with the order.

“The completion of the MSE project, including the replacement of MISO’s legacy systems and software with the integration of new market engines into MISO’s systems, is a necessary prerequisite to development of the software and systems needed to incorporate DERA in the [RTO]’s markets,” it said.

MISO also said it wants to prioritize work on its much-delayed Multiple Configuration Resources (MCR) initiative, which is intended to improve modeling of different combinations combined cycle unit types. When completed alongside the MSE project, MCR “is expected to provide reliability benefits by providing operational flexibility needed to manage the MISO region’s increased reliance on intermittent resources, such as wind and solar, to meet the region’s baseload demand needs,” the RTO told FERC.

“While MISO recognizes the benefits of promoting distributed energy resource participation in its wholesale markets through the addition of distributed energy resource aggregations, the benefits of these aggregations are unknown and relatively limited by the existing retail regulatory construct in many of the states in the MISO region.”

Environmentalists, consumer advocates and state regulators said the 2029 date was unacceptable.

The Organization of MISO States said it “recognizes the importance and benefits of MSE and MCR but questions MISO’s purported inability to pursue a parallel path for the implementation of MCR and Order 2222. MISO does not provide sufficient evidence why parallel implementation is not possible outside of a generic description that pursuing these changes simultaneously would increase the risks to reliably implement these products.”

OMS noted that PJM proposed a 2026 effective date, after implementing its new market clearing engine and Enhanced Combined Cycle model in 2025. “From the testimony MISO provided, it is unclear why MISO cannot do the same.”

Filing jointly, groups including the Natural Resources Defense Council, Sierra Club and the Union of Concerned Scientists noted that MISO’s proposed date would push back DERA participation to “nearly 10 years after the commission issued Order No. 2222 and nearly 14 years from the commission’s publication of the Notice of Proposed Rulemaking that led to Order No. 2222.”

“In essence, MISO is arguing that its markets must remain unjust and unreasonable and unduly discriminatory with regard to DERAs for nearly a decade while it sorts out technology issues that it ought to have been aware of and planning for since well before the commission issued Order No. 2222,” the groups said.

Advanced Energy Management Alliance argued that “MISO has not provided a reasonable explanation for such an extended implementation timeline given the rapidly evolving needs of consumers and the overall electric grid.” Similarly, Advanced Energy Economy and the Solar Energy Industries Association jointly argued that “by choosing to implement other initiatives over compliance with Order No. 2222, MISO is choosing to keep barriers to participation of DER aggregations in place nearly a decade after the commission first sought to remove them.”

Utility and TO Support

In contrast, MISO member utilities were largely supportive of the timeline, agreeing with the RTO on the complexity of the work.

“In permitting thousands of new generation resources to access wholesale markets, Order No. 2222 requires enormous technical planning to ensure that local distribution and transmission systems are upgraded to accommodate the new resources; that market rules, IT systems and data requirements are sufficient to allow coordination of these new resources without jeopardizing safety, reliability or cybersecurity; and preservation of appropriate roles and authorities for both state regulators and local distribution system owners,” Consumers Energy said.

“This is no small task, as MISO’s filing makes clear — particularly when implementation must take place alongside efforts to address other critical priorities of RTOs and ISOs, including reliability, resiliency, customer affordability and a seismic shift in the electric grid’s underlying resource mix.”

Alliant Energy said it “generally supports the changes as filed, recognizing that there is still much to learn and understand regarding the operation and impact of DER aggregations in MISO’s markets.” Ameren said it “appreciates MISO’s independent assessment of its current capabilities and supports MISO’s determination that the identified software improvements need to be completed before other initiatives can be launched.”

While noting “potential revisions … are needed,” MISO transmission owners also supported the effective date.

“MISO has undertaken multiple initiatives … to address the unique and complex challenges to electric system reliability in the MISO region,” they said. “Completion of these initiatives is expected to bring immediate and quantifiable reliability and economic benefits to the MISO region. At the same time … only three states in the MISO footprint currently permit retail demand resource aggregation, which could significantly limit participation of such aggregations in MISO’s markets.”