FERC staff asked NYISO to provide additional detail on the ISO’s proposed tariff revisions for integrating distributed energy resource aggregations into its markets, including a rationale for its 10-kW minimum (ER23-2040).

FERC’s July 18 deficiency notice requested an explanation for the 10-kW threshold, “as opposed to another threshold,” and asked whether the ISO’s position would change once it deploys the automation features it is currently developing. State regulators and clean energy groups have protested the 10-kW minimum, which the ISO said was needed to save staff time reviewing aggregations for interconnection. (See NYISO Defends DER Aggregation Proposal, 10-kW Minimum.)

FERC’s letter also sought detail on other revisions, including how long utilities would have to review DER reliability and safety study results and what the review would entail. Staff also asked what would constitute a “material modification” to a DER and how the ISO would conduct its aggregation derating process.

Additionally, FERC asked NYISO to justify its new DER metering and telemetry requirements, explain why it is appropriate to use certain reference levels for aggregations, and expand on its definitions related to the elimination of locational-based marginal pricing and bid-based reference levels for aggregations.

NYISO must respond to FERC’s letter by Aug. 17.