FERC on Thursday partially accepted NYISO’s second compliance filing for Order 2222, directing the ISO to submit another within 30 days to correct several inconsistencies in its tariff revisions allowing distributed energy resource aggregations to fully participate in its markets (ER21-2460-003).

The commission found NYISO’s revisions listing what constitutes a small generating facility “appear to refer to the same type of interconnection” in two different places. The commission told NYISO to either remove one of the listings or explain why including both is not redundant.

FERC also found that NYISO had revised the definition of energy resource interconnection service (ERIS) in only one of the two relevant sections of its tariff, leaving the other unchanged.

Third, FERC said that NYISO’s revisions concerning market participation agreements, although partially settled, still included language from the first compliance filing that had already been found to be noncompliant. FERC said NYISO needed to remove “language requiring aggregators to attest that the aggregation has been authorized by the distribution utility and relevant electric retail regulatory authorities to participate in NYISO’s markets.”

Lastly, FERC directed NYISO to submit informational filings every six months detailing its stakeholder process in developing ancillary service market rules allowing DER aggregations to participate until Dec. 31, 2024, by which it needs to submit yet another compliance filing that includes the proposed rules. (See FERC Clarifies CAISO, NYISO Order 2222 Rulings.)

FERC partially approved NYISO’s first compliance filing in June 2022, with the ISO submitting its second later in November. In the next month, the commission granted NYISO an extension until 2026 to fully complete Order 2222 implementation, although the ISO said at the time that it might not need that long. (See FERC Gives NYISO Until 2026 to Complete Order 2222 Compliance.)