Been digging into FERC Order 2222 and how it's going to affect distributed energy resources in New England. The compliance deadline was December 2022 but ISO-NE is still working through implementation details. This could completely change how we handle energy storage and solar+storage projects for our commercial clients. Anyone else tracking these developments in their region?
FERC Order 2222 Implementation - Anyone tracking this?
Randy here - MISO filed their compliance plan last fall but it's pretty limited compared to what we're seeing in other RTOs. The aggregation minimum is still 100 kW which locks out a lot of smaller DER projects. TVA territory is completely exempt since they're not under FERC jurisdiction. Yvonne, are you seeing any actual market participation yet or is everything still theoretical?
Still mostly theoretical Randy. Eversource has been talking about it but no concrete programs yet. The metering and communication requirements are the biggest hurdle I'm seeing. Most of my clients with behind-the-meter storage don't have the necessary telemetry equipment. Central Maine Power estimated it would cost $15,000-25,000 per site just for the metering upgrades.
Frank from Portland here. CMP's estimate sounds about right based on what I'm seeing. The bigger issue is liability and performance requirements. FERC wants these DER aggregations to perform like traditional generators but most commercial solar+storage systems weren't designed for that level of reliability. It's going to take years before we see meaningful participation, especially for smaller facilities.