Commissioner Christie’s Concurrence in MISO Order No. 2222 Compliance Proceeding, ER22-1640

Docket Nos. ER22-1640-000, ER22-1640-001

I concur with today’s order.  I write separately to address the order’s determination regarding MISO’s proposed locational requirements to comply with Order No. 2222.[1]

The pricing mechanism used in all RTO energy markets is Locational Marginal Pricing (LMP), which sets prices that are paid to generation resources at the node.  By requiring each RTO/ISO “to establish locational requirements for distributed energy resources to participate in a distributed energy resource aggregation that are as geographically broad as technically feasible,”[2] Order No. 2222 essentially urged RTOs/ISOs to pay compensation differently to this one category of resources — Distributed Energy Aggregated Resources (DEARs) — with a pricing mechanism set more broadly than nodally in energy markets.  That directive raises obvious issues of undue preference toward DEARs and undue discrimination against the other resources being paid LMP.

Indeed, in MISO’s compliance filing, MISO proposes that DEARs must be aggregated to a single Elemental Pricing Node (EP Node) for participation within MISO, explaining that “[t]his aggregation matches the granularity of MISO’s dispatch, allowing DEARs to be priced equivalently with other resources participating in MISO’s Energy and Operating Reserve Markets.”[3]  MISO’s proposal to price DEAR compensation at the node is technically feasible and is economically efficient, non-discriminatory, and fair because it treats all resources similarly.  While I believe we should accept MISO’s proposal right now rather than make MISO produce more paperwork, since this order at least does not reject MISO’s nodal pricing proposal, I will concur.

For these reasons, I respectfully concur.