MISO surprises with FERC Order 2222 implementation date

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. And, MISO has decided to work on Multiple Configuration Resources ahead of the Order 2222 market participation model. As a result, MISO’s implementation date is beyond New England ISO.

It remains to be seen what comes out of 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 is FERC Order 2222, and what does it mean for renewable energy?

MISO’s primary reasoning

All Independent System Operators (ISOs) prioritize market improvements based on FERC orders and market participant suggestions. MISO is in the middle of the Market Systems Enhancement (MSE) project, taking a modular approach to market systems that have not been automated since the 2005 market start date.

By choosing to work on an improvement related to modeling multiple combined-cycle units, called Multiple Configuration Resources or MCR for short, MISO is delaying the market participation model for implementing Order 2222. 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 from October 2020, MCR implementation is complex even when compared to Ancillary Services market due to the requirement for a new market solver. That new market solver would address the need for seven different configurations of a combined cycle unit.

Additional reasons for MISO’s longer timeline include the need for communications with distribution utilities from MISO’s control room. Currently, MISO only communicates with transmission owners and asset owners interconnected to the transmission system. With Order 2222, MISO must coordinate dispatch with distribution utilities that own distribution system assets. And MISO says it needs time to set up this communications system with the utilities.

MISO control room (Courtesy: MISO)


Multiple Configuration Resources (MCR) is suddenly in the limelight because of MISO’s market improvement schedule. As seen in the PJM and ISO-NE markets, a natural gas industry-driven Minimum Offer Pricing Rule (MOPR) is making news. 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 are fought at ISO-NE.

So, is MCR going to be MISO’s MOPR? An MCR would enable MISO to model natural gas combined cycle units appropriately in the MISO market model. It is well documented that MISO is concerned about reliability given the winter storm in Texas last year and hurricanes in the south region. However, by prioritizing natural gas-related market improvements over clean distributed energy resources such as solar and storage, MISO is stepping into the gas industry versus renewable industry MOPR battles typically found in the northeast.

MISO plans for 2022-2024

MISO is working on key supporting market systems that are already baked in and received stakeholder buy-in, including automating a tool for Demand Response Resources. MISO is also automating market model manager who ensures the market registration process synchronizes with any model updates. Otherwise, MISO real-time energy market systems won’t show accurate pricing at their market nodes.

Automating the current market system includes financial settlement systems. And distribution companies like Ameren-Illinois are already working on those improvements because of their state legislation. According to Ameren, Illinois passed energy legislation last year that envisions a dynamic relationship with customers installing distributed energy devices.

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

According to Voltus, Aggregators of Retail Customers (ARCs) are proactively automating their existing tools and processes to allow for batch loading of DERs. Any new tools or processes are expected to be minimum for utilities to comply with this FERC Order 2222 since utilities have interconnection rules in place for DER interconnections. Bulk data uploads would streamline the process for utilities like Ameren and aggregators.

However, MISO said they are concerned about the volume and scalability impact of 100 kW DERs on market systems, even though there is little evidence since multi-nodal aggregations are not allowed 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.

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. When Voltus petitioned FERC, the main topics for proposed discussions included variation in ISO compliance filings for metering and telemetry, lack of multi-nodal aggregation for maximizing DER participation, and ISO deference to distribution utilities for operational coordination.

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

There is another underlying timeline that is unique to MISO. It is widely anticipated that MISO will release the next tranche of Multi Value Projects (MVPs) in the summer. As a result, most state regulators will focus on cost allocation of MVPs in the north and south region since MISO filed at FERC a new process that allocates costs per region. Hence MISO states focus would shift to MVP cost allocation from Order 2222.


Distributed energy resources provide reliability and affordability, and all state commissioners want that. FERC wants to keep transmission customer rates just and reasonable. Hence both state and federal objectives are aligned. So, FERC should weigh in and ensure ISOs, including MISO, implement Order 2222 in 2024-26, not five years later.

For the Voltus petition at FERC, widespread support was received from 16 commenters, including the ISO/RTO Council, of which MISO is a member. Google, Sunrun, Tesla, and industry associations Advanced Energy Economy (AEE) and Advanced Energy Management Alliance (AEMA) 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 (NRECA) were the opposing minority. Hence, the focus shifts to FERC scheduling the technical conference after MISO and SPP file their compliance plans in April.

Source: Renewable Energy