MISO surprises with FERC Order 2222 implementation date

Courtesy: Sungrow EMEA/Unsplash

Midcontinent Independent System Operator (MISO) surprised the entire stakeholder community with a 2030 proposed implementation date for complying with FERC’s Order 2222, which opened wholesale energy markets to distributed energy resources. MISO’s primary reasoning for the long lead time is staging several enabling market systems, including automating the current Demand Response Tool. MISO has also decided to focus on Multiple Configuration Resources before the Order 2222 market participation model. As a result, MISO’s implementation date is beyond New England ISO.

It remains to be seen what happens at the yet-to-be-scheduled FERC Technical conference on 2222. MISO’s long implementation date is another reason FERC should schedule a technical conference sooner than later. Consumers will benefit if FERC guides MISO and other ISOs within its jurisdiction to implement Order 2222 in the 2024–2026 time frame.

Background: What does FERC Order 2222 mean for renewable energy?

MISO’s primary reasoning

All Independent System Operators, (ISOs), prioritize market improvements based FERC orders or market participant suggestions. MISO is involved in the Market Systems Enhancement Project (MSE). MISO uses a modular approach to market system that have not been automated since 2005.

MISO is delaying implementation of Order 2222 by choosing an improvement in modeling multiple combined cycle units, also known as Multiple Configuration Resources (or MCR) for short. MISO’s proposed approach chooses combined-cycle natural gas unit modeling over distributed energy resources such as solar and storage.

According to the MISO presentation of October 2020, MCR implementation was complex even when compared with Ancillary services market. This is due to the need for new market solvers. This new market solver would address seven different configurations for a combined cycle unit.

Additional reasons for MISO’s longer timeline include the need for communications with distribution utilities from MISO’s control room. MISO communicates with only transmission owners and those who are interconnected to the transmission network. Order 2222 mandates that MISO coordinate dispatch with distribution utility owners who own distribution system assets. MISO states that it will take time to establish the communications system with utilities.

MISO control room (Courtesy: MISO)


Multiple Configuration Resources (MCR) is suddenly in the limelight because of MISO’s market improvement schedule. A minimum offer pricing rule (MOPR), driven by the natural gas industry, is making news in the PJM market and ISO-NE markets. PJM finally filed a revised MOPR that addresses PJM state’s concerns around renewable energy goals and mandates. Recall, New Jersey threatened to leave PJM’s capacity market and then withdrew once PJM started working on the revised MOPR. Similar MOPR battles can be found at ISO-NE.

So, is MCR going to be MISO’s MOPR? An MCR would allow MISO the ability to model natural gas combined cycles units accurately in the MISO market model. MISO is worried about reliability after the Texas winter storm and hurricanes in the South. MISO is now stepping in to the gas industry against the renewable industry MOPR battles, which are typically found in the northeast by prioritizing natural-gas-related market improvements over clean distributed energie resources such as solar or storage.

MISO plans for 2022-2024

MISO is working on key support market systems that are already built in and have received stakeholder buyin. MISO is also automating the market model manager, who ensures that market registration processes are synchronized with any model updates. Otherwise, MISO real-time energy market systems won’t show accurate pricing at their market nodes.

Automating the market system includes financial settlements systems. Ameren-Illinois is one of the distribution companies that has been working to improve their state legislation. Ameren claims that Illinois passed energy legislation last spring, which envisions a dynamic relationship between customers who install distributed energy devices.

Can Ameren-Illinois and the state of Illinois pave a path forward for “DER Light”?

Voltus reports that Aggregators of Retail Customer (ARCs), are automating their existing processes and tools to batch load DERs. Utility interconnection rules already exist for DER interconnections so any new tools or processes will be minimal. Bulk data uploads would simplify the process for utilities like Ameren, aggregators, and others.

MISO expressed concern about the impact of 100 kW DERs in volume and scalability on market systems. This is despite the fact that there is very little evidence. Multi-nodal aggregations, however, are not permitted under the current MISO proposal.

CPower, an energy aggregator similar to Voltus, asked MISO if a “DER light” market could be implemented in a shorter timeframe.

The FERC Technical conference can shed light

MISO’s long implementation date makes a case for FERC to approve Voltus’s petition for a technical conference, specifically having a panel of ISO market design experts on 2222 implementation timelines. The main topics for discussion at Voltus’s petition to FERC included variations in ISO compliance files for metering, telemetry, and lack of multinodal aggregation for maximising DER participation.

ISO implementation dates were an afterthought, but MISO’s 2030 date makes the implementation timeline a hot priority.

MISO has a unique timeline. It is expected that MISO would release the next tranches of Multi Value Projects in the summer. Since MISO filed at FERC a process that allocates costs by region, most state regulators will be focusing on MVP cost allocation in the north and southern regions. Therefore, the focus of MISO states would shift to MVP cost allocation starting with Order 2222.


All state commissioners support distributed energy resources because they provide reliability and affordability. FERC wants transmission customer rates to remain reasonable. Both federal and state objectives align. FERC should therefore weigh in and ensure that ISOs, which include MISO, implement Order2222 in 2024-256, not five years later.

16 commenters supported the Voltus petition at FERC. This included the ISO/RTO Council of which MISO is a part. Google, Sunrun, Tesla, as well industry associations Advanced Energy Economy, (AEE), and Advanced Energy Management Alliance, (AEMA) all supported the Voltus Petition. Even MISO’s distribution utility Ameren supported the need for the technical conference.

Only the American Public Power Association, (APPA), and National Rural Electric Cooperative Association were in the opposition minority. Hence, the focus shifts towards FERC scheduling a technical conference after MISO/SPP have filed their compliance plans in April.

  • Rao Konidena is an independent consultant and focuses on providing support in policy and testimony, business development, training, and assistance in wholesale energy markets. Rao enjoys working with solar and storage developers, as well as clients who are environmental and consumer advocates.

    Rao was most recently a Principal Advisor for Policy Studies at Midcontinent ISO (MISO), where he worked on energy storage and distributed energies. Rao worked at MISO in a variety of management and non management roles, including those relating to resource adequacy and economic planning. He also had responsibilities for policy functions.

    Rao is an engineering mentor to middle school students who are participating in the Future City competition. Rao is Co-President of the Finnish American Chamber of Commerce – Minnesota (FACC-MN), and on the Board of Ever Green Energy and Minnesota Solar Energy Industries Association (MnSEIA).

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