CAISO Compliance filing with Order No. 2222 DER Aggregations

Docket No(s): ER21-2455

About Proceeding 

 In CAISO’s Order No. 2222 compliance filing, CAISO states that it proposes incremental changes to align with the final rule, such as: lowering the DER aggregation minimum capacity requirement from 500 kW to 100kW; providing an opt-out for small utilities; revising its definition to match the Commission’s definition; creating a heterogenous DER aggregation model that can include demand response; clarifying that a DER aggregation may not receive double compensation from retail programs for services it provides the CAISO markets; and requiring DER aggregations to notify CAISO when their information changes due to the modification of a distributed energy resource.  CAISO requests an effective date of no later than November 1, 2022, for the tariff sections that pertain to heterogenous DER aggregations, as the required enhancements are substantial and will be implemented as part of its 2022 Fall software release for which a precise date has not been established.  For all other proposed tariff revisions, CAISO requests an effective date contemporaneous with the Commission’s approval of such revisions.

Why of Interest 

This compliance filing is of interest to the public because proposed tariff revisions implementing the Commission's landmark rule Order No. 2222 would remove barriers to the participation of Distributed Energy Resources (DER) aggregations in the capacity, energy, and ancillary service markets operated by RTOs/ISOs.  Although CAISO was the first RTO/ISO to establish a DER aggregation model, it is filing to fully comply with the requirements of Order No. 2222.  This filing raises issues related to participation of new products and technologies and market design reforms.