FERC should reject MISO’s Order 2222 compliance filing

By Rao Konidena FERC should not get carried away by MISO’s multiple stakeholder iterations to put together the Order 2222 compliance proposal. No other ISO has proposed a 2030 implementation date and the reasons for a longer lead time are not unique to MISO. Even though FERC explicitly mandated that DERs not enter the generator interconnection queue, MISO’s proposal looks like the queue because of an increased role for distribution utilities. In addition to the long implementation date and $60,000 interconnection study deposit requirements, MISO’s proposal does not clarify retail and wholesale market participation for net-metered DERs. MISO’s proposal does not move the

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