SPP’s latest attempt to comply with FERC Order 2222 has resulted in the commission’s partial acceptance and a directive to make another compliance filing. 

FERC on March 1 ordered the RTO to submit its filing by April 30 and to update the commission on implementation timeline milestones associated with the target effective date in the third quarter of 2025 (ER22-1697). 

The commission found several areas of concern with SPP’s proposed tariff revisions to comply with Order 2222’s requirements removing barriers so distributed energy resource (DERs) aggregations can participate in RTOs’ and ISOs’ capacity, energy and ancillary service markets: 

• • compensation for demand response in heterogeneous aggregations. 
  • attestation requirements for aggregators. 
  • clarity around interconnection requirements. 
  • the potential for double-counting services.  

Responding to the Missouri Public Service Commission’s request for more stakeholder engagement on the part of SPP, FERC urged the grid operator to work with distribution utilities, relevant electric retail regulatory authorities and other stakeholders to ensure its implementation process complements any state-level changes to comply with Order 2222. 

“We encourage SPP to explore use of a stakeholder group to promote transparency, and in particular, to share information about progress on the major software and process changes to core SPP systems necessary for implementation,” the commissioners wrote. 

SPP made its first compliance filing in May 2022. That August, FERC staff issued a data request advising SPP that more information was necessary to process the filing. SPP filed its response in October. 

The proceeding has drawn more than three dozen intervenors.