Third post on the Order No. 2222 compliance filings issued on June 17, 2022: “CAISO 2222 Order” and the “NYISO 2222 Order.” This post covers the topics: Locational Requirements; Information and Data Requirements Metering; and Telemetry System Requirements.
Topic 6: Locational Requirements
Order No. 2222 requires each RTO/ISO to establish locational requirements for DER Aggregations that are as geographically broad as technically feasible. Each RTO/ISO must provide a detailed, technical explanation for its proposed geographical scope. This issue has become quite controversial, as many RTOs/ISOs have proposed only single node Aggregation.
Given that the CAISO is one of very few RTOs/ISOs proposing multi-nodal Aggregation, this issue was not discussed.
NYISO proposed that along with its Transmission Owners (NYTOs), on an annual basis, it will identify Transmission Nodes and associated distribution feeder lines to which individual facilities may aggregate and try to maximize the area of the distribution system covered while minimizing bulk power system reliability concerns. FERC generally accepted this proposal but found it lacking in detail. FERC found the NYISO Tariff insufficiently clear regarding how NYISO will identify or change its Transmission Nodes, as it did not include the criteria that it will use to establish Transmission Nodes or update them. FERC declined a request for a formal stakeholder process to map NYISO Transmission Nodes.
Distribution Factors and Bidding Parameters
FERC requires RTOs/ISOs to establish market rules that address distribution factors and bidding parameters for DER Aggregations, if multi-node Aggregations are allowed, in order to: (1) require that DER Aggregators give to the RTO/ISO the total DER Aggregation response that would be provided from each pricing node, where applicable, when they initially register their Aggregation, and to update these distribution factors if they change; and (2) incorporate appropriate bidding parameters into its participation models as necessary to account for the physical and operational characteristics of DER Aggregations. In addition each RTO/ISO with multi-node Aggregations must either: (1) incorporate appropriate bidding parameters that account for the physical and operational characteristics of DER Aggregations; and/or (2) adjust the bidding parameters of the existing participation models to account for the physical and operational characteristics of DER Aggregations. Given that only CAISO has proposed multi-nodal Aggregation, this issue was only relevant to it.
FERC found CAISO’s approach satisfactory in that Aggregators provide to CAISO distribution factors with each bid reflecting the total Aggregation response that would be provided from each pricing node and register default distribution factors in CAISO’s master file. And, Aggregators must submit the common bid components for supply resources, and bid components specifically needed for Aggregations, including the distribution factor, ramp rate, minimum and maximum operating limits, energy limit, and contingency flag. The CAISO submitted clear protocols for its requirements.
In short, the CAISO has presented a model as to how the FERC requirements for multi-nodal Aggregations should work, but it remains to be seen how common multi-nodal Aggregations will be in the other RTOs/ISOs.
Topic 7: Information and Data Requirements
Each RTO/ISO must establish market rules that address information requirements and data requirements for DER Aggregations relating to the physical and operational characteristics of its Aggregations; a list of the individual resources in each Aggregation; and the necessary information that must be submitted for the individual DERs in an Aggregation. FERC also required DER Aggregators to provide aggregate settlement data for their DER Aggregations and to retain performance data for individual DERs for auditing purposes.
The CAISO’s pre-existing requirements evidently passed muster and were unprotested, such that the issue was not addressed.
The faults that FERC found with the NYISO proposal were largely in the nature of omissions. NYISO neglected to require the DER Aggregator to update its list of individual DERs. The NYISO Tariff did not include the information and data that a DER Aggregator must provide about the physical and operational characteristics of its Aggregation; necessary information that must be submitted for the individual DERs; or the physical parameters that DER Aggregators must submit. Rather, NYISO submitted an “unfinished proposal” to include such material in non-Tariff documents. FERC found this approach unacceptable and required NYISO to file a process for gathering and identifying the needed information.
The NYISO 2222 Order reflects an overarching theme of the orders, that key elements of a DER Aggregation program must not be left to business practice manuals.
Topic 8: Metering and Telemetry System Requirements
Each RTO/ISO must establish market rules addressing metering and telemetry hardware and software requirements necessary for DER Aggregations that balance the RTO’s/ISO’s need for metering and telemetry data for settlement and operational purposes with the placing of unnecessary burdens on DER Aggregators. Each RTO/ISO has to explain why its proposed metering and telemetry requirements are necessary. In developing requirements, the DER Aggregator must be the single point of contact with the RTO/ISO, responsible for managing, dispatching, metering, and settling the individual DERs in its Aggregation and providing any required metering and telemetry information to the RTO/ISO. Also, RTO’s/ISO’s proposed metering requirements should rely on meter data obtained through compliance with Distribution Utility (DU) metering and telemetry requirements whenever possible for settlement and auditing purposes. If an RTO/ISO proposes that information come from or flow through DUs, FERC required that RTOs/ISOs coordinate with DUs and retail regulators (RERRAs) to establish protocols for sharing metering and telemetry data that minimize costs and other burdens and address concerns raised with respect to privacy and cybersecurity. FERC indicated that RTO/ISO tariffs should include a basic description of the metering and telemetry practices for DER Aggregations as well as references to specific documents that will contain further technical details. These many requirements proved somewhat difficult to fully abide by given the level of detail required.
The CAISO requires individual DERs to be directly metered by a meter that complies with the DU/RERRA rules and allows DER Aggregators to provide aggregated settlement quality meter data to the CAISO, which approach was approved. As to telemetry, the Aggregator must provide direct telemetry for the Aggregation but the CAISO accommodates the use of existing telemetry infrastructure.
FERC found that the CAISO Tariff lacked sufficient detail regarding how DERs can provide data to the Aggregator in order to meet CAISO’s aggregate telemetry requirements. The Tariff also did not specify the methods available to an Aggregator for providing telemetry to CAISO without requiring telemetry from all of the individual DERs in the Aggregation. CAISO explained that providing regulation service requires a constant telemetry signal to maintain system frequency, but neither the Tariff nor the relevant business practice manual provided detail regarding how an Aggregator could provide this constant telemetry signal without requiring the individual DERs to invest in telemetry equipment. FERC ordered these deficiencies to be fixed.
NYISO allows an Aggregator to choose to have a NYISO-authorized Meter Services Entity or applicable Member System provide the Aggregation metering services on its behalf, but the Aggregator is responsible for meeting the applicable metering standards under NYISO’s Services Tariff. Aggregators are required to provide telemetry data to NYISO.
FERC found that NYISO neglected to include a deadline for meter data submission for settlements (presumably because the deadline was in a separate tariff section applicable o all participants). FERC expressed concern that Aggregators may be in the position of compiling meter data for numerous individual DERs within an Aggregation, and that meeting the meter data submission deadline may consequently pose additional challenges for Aggregators and the issue should be discussed before the next compliance filing. FERC also found that the NYISO Tariff did not include references to the specific documents that contain further technical details. That is, a metering roadmap was missing. NYISO also lacked protocols for sharing metering data.
The NYISO Tariff similarly lacked references to specific documents that contain further technical details on telemetry requirements and data sharing. NYISO requires Aggregations to send telemetry signals 24 hours a day, seven days a week, nominally on a six-second basis, consistent with the rules for generators to allow NYISO to maintain the reliability of the New York Bulk Power System, but a roadmap to documents that provide technical detail was missing. Some objected to NYISO’s existing six-second telemetry requirement, but FERC treated that as a settled issue. NYISO has established flexible rules for small DERs with a response of under 100 kW that allows the option to utilize alternative measurement and verification tools that avoids the need for small facilities to install more costly hardware and software that is required for conventional resources.
NYISO did not comply with the requirement that, to the extent that an RTO/ISO proposes that metering and telemetry data comes from or flows through DUs, RTO/ISO protocols must exist that minimize costs and other burdens and address concerns raised with respect to privacy and cybersecurity.
It will be difficult for most RTOs/ISOs to fully comply with the myriad standards and explanations required for metering and telemetry in their first compliance filings. RTOs/ISOs should submit compliance filings that assume Aggregators are not familiar with pre-existing standards.