FERC has accepted MISO’s second try at Order 2222 compliance, allowing MISO time to prepare through mid-2029 before it fully accepts aggregators of distributed energy resources into its markets in 2030.

The commission said in a Jan. 16 order that MISO this time provided adequate explanation for the delay into 2030 and pledged that creating a multiple configuration resource model will take a backseat to finishing Order 2222 (ER22-1640-003).

FERC accepted MISO’s rationale that its underlying computer systems need work over the next four years and called the wrap-up date a “reasonable effective date that is appropriately tailored for its region and implements Order No. 2222 in a timely manner.”

FERC also decided MISO this time around provided enough additional analysis to support its call to limit aggregations to a single pricing node. FERC directed in Order 2222 that aggregations should be as locationally broad as technically feasible.

The commission disagreed with some stakeholders that MISO’s effective date is essentially the original 2030 timeframe MISO proposed. FERC said this time, MISO prioritized Order 2222 compliance on its to-do list over its initiative to create a multi-configuration resource model but had to account for several more months to roll out its new market platform and get its systems ready for DER aggregations’ registration and enrollment and settlements.

MISO said, “additional systems enhancements and process updates that were not contemplated at the time of MISO’s initial compliance filing are now also required to achieve … final implementation.”

MISO expects to have its new, modular market platform fully operational in late 2025. Beyond that, MISO said improvements to its locational enrollment system needed for DER registration are underway and expected to be completed in mid-2026. It also said updating its settlement systems to accommodate DER aggregations will take until mid-2028.

In its first decision in 2023 on MISO’s plan, FERC said MISO’s 2030 finish date wasn’t timely enough. The RTO explained it first needed to replace its market platform before it has the technological capability to register, enroll and facilitate offers from DER aggregations. (See FERC: MISO’s 2030 Finish Date on Order 2222 Compliance not Soon Enough.) In response to the order, MISO divided its plan to allow DER aggregations in its markets into two stages.

MISO proposed a two-step approach to Order 2222 compliance. First, it would use an existing demand response resource participation category to get aggregations of distributed resources participating sooner — albeit on a limited basis — and providing energy, contingency reserves and capacity through behind-the-meter generation or controllable load. MISO would begin registering DER aggregations under its demand response resource (DRR Type I) participation model by Sept. 1, 2026, and begin participation by June 1, 2027. DER aggregations would be limited to 1 MW or larger under the demand response participation.

MISO would roll out its comprehensive Distributed Energy Aggregated Resource model at the beginning of 2030. It plans to register aggregations beginning June 1, 2029, allow DER aggregations to participate in its energy and ancillary services by Jan. 1, 2030, and finally open full market participation to aggregations by June 1, 2030. (See MISO Offers 2-stage Plan for DER Aggregations in Markets.)

FERC: Demand Response Participation Doesn’t Fit with Order 2222

In its Jan. 16 order, however, FERC said MISO’s prerogative that a DRR Type I participation approach could serve as the first phase of Order 2222 compliance is wrong. The commission said MISO’s proposed 1-MW size threshold doesn’t line up with Order 2222’s 100-kW size minimum.

FERC also said MISO’s demand response placeholder doesn’t address the coordination, data requirements or means to discourage double counting of resource contributions required under Order 2222.

“We recognize that MISO’s DRR-Type I proposal was intended to be responsive to the commission’s directives on the effective date and locational requirements of Order No. 2222,” FERC said, but added that MISO nonetheless missed the mark on leveraging an existing participation model to eke out partial Order 2222 compliance.

FERC gave MISO 180 days to either file how the DRR Type I participation model can comply with Order 2222 or strike the first phase of participation altogether from its compliance plan. FERC said if MISO decides to remove the DRR Type I component, it’s free to make an independent filing to FERC to seek approval of the temporary participation method for DER aggregations.

MISO did not return RTO Insider’s request for comment on whether it would salvage the DRR Type I aspect for a separate filing to allow DER aggregations to provide some services by the middle of 2027.