MISO is insisting to FERC that it’s appropriate to take until 2030 before beginning the complicated task of opening its markets to distributed energy resource aggregators.

The grid operator filed a defense of its Order 2222 compliance plan with the commission last week, calling its proposed effective dates for registration (October 2029) and aggregations’ market participation (March 2030) “reasonable and appropriately tailored for the MISO region.” (See MISO Finalizes Plan for DER Market Participation in 2030.)

This comes after several members, state regulators and stakeholders said they were perplexed as to why MISO couldn’t accept DER aggregations after it replaces its market platform in 2024 or 2025. (See MISO Stakeholders Protest RTO’s Order 2222 Implementation Timeline.)

The RTO reminded FERC that its Order 2222 “recognized regional differences and directed each ISO/RTO to propose an implementation timeline that is reasonable for its respective markets” (ER22-1640).

Responding to the Organization of MISO States’ criticism that its plan is too drawn out, MISO said regulators can encourage participation in existing retail DER programs. The grid operator said retail regulatory authorities “have both the ability and authority to further develop and promote these programs” while MISO develops the systems and software necessary to implement Order 2222’s requirements.

MISO contended the “time between now and 2029 will be best used to work on other market and underlying system enhancements that it believes will make the full DER implementation process seamless and able to provide the most value.”

It also addressed arguments from clean energy and solar trade associations that the lengthy delivery time is tantamount to seeking a waiver of FERC compliance obligations. The RTO said that in addition to completing its market platform replacement, it needs another four years to overhaul its registration and enrollment system that is more than 10 years old. It also explained it must first introduce a multi-configuration resource participation model before it can tackle offers from DER aggregations.

MISO plans to use elements of its electric storage participation plan for DER aggregations. The aggregations must self-commit in the RTO’s markets based on their own forecasts and will be limited to a single pricing node.