Understanding FERC Order No. 2222

May 8, 2025

FERC Order No. 2222 Explainer: Facilitating Participation in Electricity Markets by Distributed Energy Resources

Introduction

  • FERC Order No. 2222: Issued in 2020, with updates in 2021 by the Federal Energy Regulatory Commission (FERC).
  • Purpose: To enable distributed energy resources (DERs) to participate in electricity markets run by regional grid operators.
  • DERs Include:
    • Electric battery storage systems
    • Rooftop solar panels
    • Smart thermostats
    • Energy efficiency measures
    • Thermal energy storage systems
    • Electric vehicles and charging equipment

Concept of Aggregation

  • Aggregation: Bundling of multiple small DERs to form a sufficiently large group to participate in the energy market.
  • Aggregator: An entity that combines DERs and participates in the market, sharing compensation back to individual DERs.

Importance of Order No. 2222

  • Opportunities: DER owners can participate in electricity markets and earn money.
  • Location Requirements: Participation is possible in regions with Regional Transmission Organizations (RTOs) or Independent System Operators (ISOs), excluding Texas ERCOT.

FERC Overview

  • FERC's Role: Regulates the wholesale sale and transmission of electricity, natural gas, and oil in interstate commerce.

Wholesale Sales of Electricity

  • Wholesale vs. Retail: Wholesale involves sales to utilities that resell it to end users.
  • FERC's Goal: Enable DER aggregators to make wholesale sales in organized markets.

Role of RTOs

  • RTOs' Function: Non-profit entities managing reliable and safe transmission of electricity.
  • Market Types:
    • Energy Markets
    • Capacity Markets
    • Ancillary Service Markets

Enabling DER Participation

  • Reducing Barriers: FERC is simplifying rules for DER aggregations to participate in markets by lowering minimum size requirements and establishing new market rules.

Current Barriers and Solutions

  • Barriers: Market rules designed for traditional resources, not DERs.
  • Solutions: FERC mandates RTOs to create rules for DER aggregations, addressing size, location, metering, and coordination requirements.

Implementation Timeline

  • Implementation by RTOs: Varies by region, with timelines for CAISO, NYISO, ISO-NE, SPP, PJM, and MISO ranging from 2024 to 2030.

Participation Opportunities

  • Aggregation Services: Expected rise of entities offering aggregation services for DERs.
  • Considerations: Participants should compare offers and consider existing state and local programs.

Further Information

  • Contact: FERC's Office of Public Participation for more details on opportunities and participation.