Distributed solar stakeholders must take comfort in FERC’s data requests sent to NYISO and CAISO. There are seven instances where solar is mentioned in the FERC letter to NYISO. Most of the questions focused on how distributed solar would operate within the ISO market construct through an aggregator and how the ISO would coordinate with the distribution utility to facilitate solar and storage dispatch. This blog focuses on two compliance elements out of the possible ten topics, because FERC staff had many questions on NYISO’s market model, and how NYISO would coordinate with the distribution utilities and the retail authorities. Taking the cue from FERC’s letters to NYISO and CAISO, ISO staff at MISO, SPP, PJM, and ISO-NE would be well served. BackgroundNew York Independent System Operator (NYISO) did not ask for an extension and filed their compliance plan at FERC on July 19, 2021, the original due date. However, on October 1, FERC staff sent twenty-one “please explain” questions to NYISO regarding their Order 2222 compliance filing. For distributed solar and storage stakeholders, these FERC letters (one sent to California ISO (CAISO) and who also submitted their compliance filing) offer clues for FERC’s attention and focus on the aggregation of distributed energy resources and their role in the energy market construct. Both NYISO and CAISO did not convene stakeholders to put together their compliance filings. But the rest of the ISOs did. Hence these questions offer guidance for ISO staff and stakeholders at PJM, ISO-NE, MISO, and SPP, since they still have time to file their compliance plans. FERC had many questions on the eligibility to participate in NYISO markets for DER Aggregator (DERA) and the coordination between NYISO, the Aggregator, and the Distribution Utility (DU). Hence this blog focuses on these two compliance elements out of the possible

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