Notational Order 2022-03-22
Advance Notice of Proposed Rulemaking: Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection
Docket No(s): RM21-17
About Proceeding
The Advance Notice of Proposed Rulemaking (ANOPR) seeks public comment on potential reforms in three specific areas: reforms for longer-term regional transmission planning and cost-allocation processes that take into account more holistic planning, including planning for anticipated future generation; rethinking cost responsibility for regional transmission facilities and interconnection-related network upgrades; and enhanced transmission oversight over how new transmission facilities are identified and paid for.
Why of Interest
This generic proceeding has the potential to result in major rules that would have broad long term impact on transmission development and cost allocation policies. The proceeding raises key issues such as transmission planning, impacts of transmission rules on development of renewable generation, and cost allocation. It also asks whether the current approach to oversight of transmission investment adequately protects customers, and, if customers are not adequately protected from excessive costs, what potential reforms may be required and are legally permissible to ensure just and reasonable rates.
Finally, it seeks comment on several other important related topics including whether action in these areas would be consistent with FERC's legal authority, consideration of consumer protection issues, coordination between individual transmission provider planning processes and regional transmission planning processes, and interregional planning.
Status Update
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Comments due
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Technical Conference
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Reply Comments due
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Post-technical conference comments due: 11/30/2021
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.
Status Update
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Comments closed 8/9/21
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Letter Order Requesting Additional Information Issued: 10/1/2021
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CAISO Response to 10/1/21 Letter: 11/1/2021
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Comments Closed: 11/23/21
Holy Cross Electric Association, Inc., D/B/A Holy Cross Energy v. FERC
American Clean Power Association v. FERC
Notational Order 2022-03-23
Energy Market/Energy Infrastructure Advisor, 301
The following requirements are prescribed by the Office of Personnel Management and used to determine minimum qualifications.