DALLAS — MISO members pondered at Board Week how quickly the full impact of Order 2222 will be felt across the footprint.
During a March 20 Advisory Committee meeting, WEC Energy Group’s Chris Plante said it’s difficult to pinpoint the contribution of aggregated DERs across MISO because state regulatory authorities have differing views on how DER aggregation programs should look.
Fresh Energy’s Mike Schowalter also predicted a “scattered approach” among MISO utilities.
MISO doesn’t yet have FERC’s go-ahead to proceed with its implementation plan. The commission said MISO has a few kinks to work out, namely how it will manage cybersecurity, dispute resolution and reformulating a go-live date sooner than MISO’s initial 2030 target. (See Stakeholders Ask MISO to Share New Order 2222 Go-live Date ASAP.)
Executive Director of Market and Grid Strategy Zak Joundi said Order 2222 means bringing together “a lot more parties,” and jurisdictions with responsibilities outside of the MISO tariff.
Minnesota Public Utilities Commissioner Joseph Sullivan said the Organization of MISO States’ annual DER surveys found approximately 12.5 GW of DERs across the footprint, some ripe for aggregations.
“I think we’re all over the map in terms of expectations,” said ITC’s Brian Drumm, representing MISO’s transmission owners. He said the complexity of the order’s aims is compounded by the fact some technology to harness aggregated DERs is undeveloped.
“This is going to take a lot of time. This is a very expansive order. There’s a lot of work to be done that’s kind of nebulous and very broad,” Drumm said.
“Where there is meat on the bone, where there is money to be made, participants will find their way into the market,” the Union of Concerned Scientists’ Sam Gomberg said. He predicted steady, slow-moving work preparing markets for DERs and then “a rapid, widespread adoption” of rooftop solar, electric vehicles and distributed storage.
Gomberg said it would be a “missed opportunity” to not prepare and be forced to “scramble” and seek a pause when MISO reaches the described DER tipping point.
MISO Director Nancy Lange asked if utilities’ distribution systems can handle aggregations efficiently and economically.
“We’ve taken steps,” Alliant Energy’s Mitch Myhre said, referencing investments in communication systems, distribution upgrades, energy management systems and fiber technology.
Xcel Energy’s Susan Rossi also said MISO’s transmission owners are investing in advanced metering management systems, calling them the “building blocks” of Order 2222.
“We’re all in the space of where to invest the money. And of course, we’re sensitive to customer affordability,” Ameren’s Jeff Dodd said. Dodd added that no RTO is far enough along in incorporating DER aggregations in the market to “steal good ideas” from.
“My sense is technically we’re capable,” Sullivan said, though he added he has reservations about utilities’ preparedness for the supply uncertainties aggregated DER offers will introduce.
MISO Director Todd Raba said recent instances of demand response gaming in MISO markets begs the question of “who’s going to be the policeman” and discourage fraud in aggregations.
“It has to be a multilevel responsibility and accountability structure. I think it’s MISO, it’s FERC, it’s state commissions. And that’s not to punt, that’s not to say that it’s no one’s responsibility,” Sullivan said.
Drumm said he believed that stopping potential exploitation of MISO’s markets by DER aggregations “falls squarely” under the monitoring duties of the Independent Market Monitor.
MISO will hold discussions on its new Order 2222 implementation date through April via the RTO’s Distributed Energy Resources Task Force. The task force was scheduled to sunset this year but has been extended through 2025.
The RTO has until May 10 to file an updated implementation plan with FERC.
“There are meetings we still have on the books before the filing,” Joundi said, encouraging stakeholders to weigh in on MISO’s second Order 2222 compliance filing.
