Only utilities seem to like MISO’s DER implementation plan

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Most commentators, including MISO states, want FERC to reject the Midcontinent ISO (MISO) proposal to implement FERC Order 2222— and allow distributed energy resources to participate in the wholesale market — by 2030. Beyond the implementation date, most comments asked FERC to reject MISO’s single node proposal in favor of a multi-nodal aggregation model. Only some distribution utilities filed in favor of MISO’s 2030 implementation date.

There are important lessons to be learnt for MISO/SPP since FERC began issuing decisions on NYISO and CAISO proposals.

Taking the cue from FERC’s decision on NYISO’s proposal, FERC is encouraging the distribution utilities to look at the incremental impacts of DER interconnections. If MISO files comments, it is not known until then if it decides against its states or FERC on the Order 2222 proposal.

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Get feedback on the MISO proposal

The general feedback on MISO’s Order 2222 proposal has been robust compared to SPP’s.

Eighteen comments were filed compared to the eight in SPPs, with the majority asking FERC to reject MISO’s long implementation date. Ten out of eighteen (55%) organizations filed comments supportive of DER providers – Advanced Energy Management Alliance (AEMA), Illinois Commerce Commission, Voltus, Michigan PSC, Entegrity Energy Partners, Solar Energy Industries Association (SEIA), Advanced Energy Economy (AEE), Public Interest Orgs, Organization of MISO States, Missouri PSC, and the Indiana Utility Regulatory Commission.

Environmental Law and Policy Center, Carmel Green Initiative, Inc., Citizens Action Coalition of Indiana, Energy Matters Community Coalition, Inc., Natural Resources Defense Council, Sierra Club, Solarize Indiana, Inc., Solar United Neighbors, Sustainable FERC Project, and Union of Concerned Scientists made up the Public Interest Orgs.

Seven out of eighteen (38%) filed comments supporting MISO’s 2030 implementation date – Xcel Energy, Entergy, Ameren, Detroit Edison, MISO Transmission Owners, Consumers Energy, and Alliant Energy. WPPI Energy raised concerns about transmission charges, which FERC may say are not within the scope of this 2222 docket.

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

Refusal to MISO

Going into the FERC docket on MISO’s proposal, it was a given that industry alliances and associations such as AEMA, SEIA, AEE, and public interest organizations would push hard on MISO to implement the Distributed Energy Aggregated Resource (DEAR) model earlier than 2030.

But what was surprising to most was the number of comments filed individually and as an organization by state commissions inside the MISO footprint favoring a DEAR implementation in parallel with MISO’s proposed Multiple Configuration Resources (MCR) market upgrade.

Michigan PSC’s statement sums up the sentiment across most stakeholders in this “push MISO hard” camp: “While there are certainly obstacles to rapid implementation, MISO has not demonstrated that these obstacles justify an implementation date that will prevent distributed energy resource aggregators from participating in MISO’s wholesale market until the next decade.”

The Organization of MISO States (OMS), which questioned MISO’s final prioritization (of sequencing MCR before DEAR), suggested that MISO implement DEAR in parallel to MCR.

This sentence from OMS comments sums up the general feeling among most stakeholders: “MISO did not propose their 2030 timeline until February 2022, which caught many parties off-guard and may have impacted the positions OMS took earlier in the stakeholder process.”

Another striking feature of OMS comments is that MISO’s proposed single node aggregation model did not go well with them in addition to public interest organizations and AEMA, SEIA, and AEE. AEE and SEIA comments showed how single nodal accumulation is a barrier for Michigan.

MISO control room. Credit:

MISO is a utility-oriented organization

Investor-owned utilities (IOUs) from Minnesota, Wisconsin, Michigan, Missouri, and Entergy from MISO’s South region all favored MISO’s proposed 2030 implementation date for the DEAR model.

Xcel Energy suggested that FERC should pause interconnecting DERs for its Minnesota utility, Northern States Power.

Entergy’s protest raised several operational coordination details. For instance, Entergy wants the MISO tariff to impose an obligation on the aggregator to contact the utility during the “pre-registration” process, entirely missing the voluntary nature of MISO’s pre-registration process.

FERC will not side with Entergy, as none of the technical issues raised provide any transparency into how Entergy would conduct its safety or reliability checks.

MISO could be affected by FERC decisions in California or New York

FERC began to weigh proposals for ISO Order 2222. On June 17, the agency sent out decisions on both California ISO and New York ISO proposal proposals.

FERC had much to say about interconnections in NYISO’s proposal to implement 2222. FERC asked NYISO to clarify that DER interconnections do not fall under Small Generator Interconnection Procedures, which is relevant for MISO because MISO’s proposal leans heavily on generator interconnection procedures and concepts for DER interconnections.

FERC also took a firm stance against NYISO regarding heterogenous aggregations, which are aggregations that combine multiple DER technologies. NYISO was directed by FERC to file a compliance report by August 17 in order to ensure heterogenous aggregations participation on the ancillary service markets.

The most important takeaway for distribution utilities from FERC’s decision on NYISO’s filing is that FERC asked NYISO to revise its tariff and that any DU review is limited to incremental impact from a resource’s participation and that has not been considered previously by the DU in its interconnection process.

This last point allows DER providers to save time on interconnection studies and help them get DERs to the wholesale market sooner than they otherwise would.


MISO has three week from June 6th to respond to any comments.

It remains to see if MISO will request an extension to FERC’s response to PJM. FERC could simultaneously send a data request both to MISO and SPP. FERC could also request the technical conference Voltus or others requested in February.