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.
Continue Reading The First Order No. 2222 Compliance Orders (CAISO and NYISO):Part 3 – Topics 6-8 (Locational Requirements; Information and Data Requirements Metering and Telemetry System Requirements)