FERC Staff Requests RTOs Report On Distributed Generation Participating In Wholesale Markets vs. Those Not Participating; Aggregation; Interconnection

FERC Staff have requested that the Commission-jurisdictional RTOs provide responses to a series of questions related to distributed energy resource (DER) participation in the RTO markets, the aggregation of DERs, and interconnection issues.

Staff's request was made in Docket No. RM18-9-000, concerning participation of distributed energy resource aggregations in markets operated by Regional Transmission Organizations and Independent System Operators

Among other things, Staff asked, "If available, please provide data on or estimates of the number of individual DERs in your region that are directly participating today in your RTO/ISO markets as compared to DERs in your region that are not participating in wholesale markets. If possible, please provide estimates by resource type and participation model (i.e., generator, demand response, etc.)."

Staff asked, "Under your RTO's/ISO's existing rules for small generator interconnection, if a DER seeks to participate in wholesale markets and plans to interconnect at the distribution level, please describe the step-by-step process by which that resource would interconnect to the system."

Staff asked, "How does your RTO/ISO define the physical boundaries of a distribution facility when determining whether a distribution facility to which a new DER seeks interconnection is already subject to an Open Access Transmission Tariff (OATT) for purposes of making wholesale sales?"

Staff asked whether the interconnection process described in response to the question listed above differ if the DER seeking to participate in wholesale markets is interconnecting behind a retail customer meter (whether on the distribution or transmission system)

Staff asked, under the relevant interconnection process and assuming all of the individual DERs in the aggregation are new resources, which of the following would apply: (1) an aggregation of DERs located at multiple points of interconnection would be studied as one aggregated resource by your RTO/ISO and require only a single Generator Interconnection Agreement (GIA); (2) each individual DER would be studied individually and require its own GIA; (3) each DER would be studied individually with the aggregation still only requiring a single GIA; or (4) a different approach (please describe if a different approach would be used).

Staff asked, in the case where at least some of the individual DERs in a proposed aggregation are existing resources already interconnected and in service, if multiple existing and new DERs were able to aggregate at separate points of interconnection across your RTO/ISO to participate in wholesale markets as an aggregation rather than as individual resources, under what circumstances would your RTO's/ISO's existing interconnection procedures and study processes apply to the individual DERs in the aggregation? If multiple existing and new DERs were able to aggregate at separate points of interconnection across the RTO/ISO to participate in wholesale markets as an aggregation rather than as individual resources, under what circumstances would your RTO's/ISO's existing interconnection procedures and study processes apply to the aggregation? Would any revisions be needed to accommodate aggregations of DERs (existing and new) at multiple points of interconnection?