October 2, 2024
FERC Grants ISO-NE Extension on Order 2222 Compliance
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FERC granted ISO-NE an extension on its Order 2222 compliance deadline, giving the RTO until Feb. 2, 2022.

FERC on Monday granted ISO-NE an extension on its Order 2222 compliance deadline, giving the RTO until Feb. 2, 2022 (RM18-9). The original deadline was July 19.

ISO-NE Order 2222
FERC headquarters | © RTO Insider LLC

Order 2222, issued last September, directs RTOs and ISOs to open their markets to distributed energy resource aggregations. (See FERC Opens RTO Markets to DER Aggregation.)

In its extension request, ISO-NE told the commission that Order 2222 compliance “requires substantial coordination.” An extension would ensure the RTO “has sufficient time to engage with relevant electric retail regulatory authorities, electric distribution companies, meter readers and other affected stakeholders,” it said, and its approach to metering and integration of demand response resources would benefit from further discussions with NEPOOL stakeholders. The extension also provides the RTO and NEPOOL time to review whether Order 2222-A, which FERC issued in March to refine and clarify some requirements in the original order, impacts its compliance proposal. (See FERC Limits State ‘Opt Out’ on DR.)

The Massachusetts Department of Public Utilities, Connecticut Public Utilities Regulatory Authority and Vermont Public Utility Commission supported ISO-NE’s compliance extension, including the ability to solicit more input from stakeholders. Advanced Energy Economy agreed with the RTO that several issues warrant further discussion and emphasized the importance of allowing stakeholders to provide feedback on ISO-NE’s proposal to ensure full compliance.

Christie Concurs, with Caveat

Commissioner Mark Christie concurred with granting an extension, but he reiterated that he would not have voted for Order 2222 if he were on the commission last September.

Christie said similar to the compliance extension requests filed by MISO, SPP and PJM, ISO-NE also illustrated “the daunting complexities and certain increased costs to consumers” that he referenced in his dissent to Order 2222-A. Christie noted that NEPOOL has already held seven committee meetings on the order. (See FERC OKs Delay on Order 2222 Compliance.)

“Since — at least at this point — the RTOs have no choice but to comply with these orders, I respectfully concur with the letter order granting ISO-NE’s request for extension of time to make its compliance filing,” Christie wrote. “I also hope that by granting the extension, ISO-NE will have more time to try to mitigate some of the potential for reliability problems.”

ISO-NE will seek votes on its Order 2222 compliance proposal and any potential amendments at the December meetings of the NEPOOL Markets, Reliability and Transmission committees. The RTO will then request a vote from the Participants Committee at its January 2022 meeting. (See “Discussing Order 2222 Compliance,” NEPOOL Markets Committee Briefs: May 11, 2021.)

Distributed Energy Resources (DER)ISO-NE

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