Fifth and final post on the Order No. 2222 compliance filings issued on June 17, 2022: “CAISO 2222 Order” and the “NYISO 2222 Order.” The post covers the topics: Modifications to List of Resources in Aggregation; Market Participation Agreements; and Effective Date.

Topic 10: Modifications to List of DERs in Aggregation

In Order No. 2222, FERC required each RTO/ISO to establish market rules that address modifications to the list of DERs in a DER Aggregation. The Commission ruled that any modification re-triggers the Distribution Utility (DU) review process, although that review could be abbreviated. FERC urged abbreviated procedures especially for an exiting DER.

This issue was not discussed as to the CAISO.

The NYISO was ordered to correct wording that allowed DU review of only incremental modifications to an Aggregation, rather than to review any modification; this correction may just be a matter of semantics.

Topic 11: Market Participation Agreements

Each RTO/ISO must establish market rules that address market participation agreements for DER Aggregators that defines the DER Aggregator’s role and responsibilities and its relationship with the RTO/ISO. The Commission stated that this market participation agreement must include an attestation that the DER Aggregation is compliant with the tariffs and operating procedures of the DU and the rules and regulations of any retail regulator (RERRA). The market participation agreements could not limit the business models under which DER Aggregators can operate.

This issue was not discussed as to the CAISO.

The NYISO’s use of its existing Service Agreement under the Services Tariff was accepted with a fix to the attestation. NYISO’s proposed attestation required the Aggregator to attest that the DU and RERRA have authorized the individual facilities and Aggregation to participate in the wholesale markets. FERC found that the attestation should instead address compliance with the tariffs and operating procedures of the DU and rules and regulations of any RERRA.

Topic 12: Effective Date

FERC required each RTO/ISO to propose a reasonable implementation date, together with adequate support explaining how the proposal is appropriately tailored for its region and implements Order No. 2222 in a timely manner.

CAISO requested an effective date no later than November 1, 2022 for the proposed Tariff sections that pertain to heterogeneous DER Aggregations, and for all other proposed Tariff revisions, CAISO requested an effective date contemporaneous with the Commission’s approval of its Tariff revisions. FERC accepted this proposal.

The NYISO’s proposed implementation timeline in the fourth quarter of 2022 also complied with Order No. 2222. NYISO also had to file a proposed effective date by which it will allow DERs in heterogeneous Aggregations to provide all of the ancillary services that they are technically capable of providing through aggregation. This proposal was accepted

The effective date issue was not at all controversial as to these ISOs because they were immediate/relatively soon, which was expected given their existing Aggregation programs. Other RTO/ISO proposed effective dates, i.e., MISO in particular, already have proven far more controversial.