ISO-NE begins work on Order No. 2222 compliance

ISO New England has started work on complying with the Federal Energy Regulatory Commission’s (FERC) Order No. 2222, Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators.  The order requires that ISOs and RTOs allow distributed energy resources (DERs) to participate in the wholesale markets and to provide all services that they are technically capable of providing through an aggregation.

ISO New England initiated the stakeholder process with a December 8 presentation from Henry Yoshimura, the ISO’s director of demand resource strategy, to the NEPOOL Markets Committee. In the presentation, Yoshimura outlined the order’s key compliance directives and the ISO’s proposed timeline for stakeholder engagement with DER developers, aggregators, distribution utilities, and state regulators.

In the order, which FERC issued in September, the commission determined that existing ISO and RTO market rules are unjust and unreasonable in light of the barriers they present to the participation of DERs in regional markets. These resources, which can include solar arrays, batteries, and other technologies connected to the distribution system, may be too small to meet the minimum size requirements to participate in the wholesale markets on a stand-alone basis, and may be unable to meet certain qualification and performance requirements. However, the commission reasoned that through aggregation, these resources might meet various size and performance requirements, and participate alongside traditional resources to provide services in the regional markets.

Therefore, Order No. 2222 requires ISOs and RTOs to amend their tariffs, as necessary, to allow distribute energy resource aggregations (DERAs) as market participants, and to address specific technical requirements of the order. Alternatively, ISOs and RTOs can demonstrate how existing tariff provisions satisfy the intent and objectives of the order.

Compliance filings are due to FERC on July 19, 2021.

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