FERC Order No. 2222 Overview and Impact

May 8, 2025

FERC Order No. 2222: Facilitating DER Participation in Electricity Markets

Overview

  • FERC Order No. 2222: Issued by the Federal Energy Regulatory Commission (FERC) in 2020, updated in 2021.
  • Objective: Enable distributed energy resources (DERs) to participate in electricity markets run by regional grid operators.
  • DERs Examples: Electric battery storage, rooftop solar panels, smart thermostats, energy efficiency measures, thermal energy storage, electric vehicles.
  • Aggregation: Combining multiple small DERs into a single bundle for market participation.

Importance for DER Owners

  • Potential Participants: Individuals with installed or planned solar panels, battery storage, smart thermostats, or electric vehicle chargers.
  • Opportunities: Earn money by participating in electricity markets through aggregations.
  • Requirements: Live in areas with RTOs/ISOs (excluding Texas ERCOT, which is outside FERC jurisdiction).

Role of FERC

  • FERC: Independent federal agency regulating wholesale electricity sales, interstate energy transmission, and licensing energy projects.
  • Wholesale vs. Retail: Wholesale involves selling electricity to utilities, whereas retail involves utilities selling to end-users.

RTOs and Electricity Markets

  • RTOs: Non-profit organizations operating transmission lines, managing regional electricity markets.
  • Markets: Include energy, capacity, and ancillary service markets.
  • Goal: Facilitate DER participation and competition in RTO markets.

Enabling DER Market Participation

  • Reducing Barriers: Allow small DERs to meet market size and performance requirements through aggregation.
  • Barriers: Market rules designed for traditional large-scale resources, not DERs.

Compliance and Implementation

  • RTO Compliance: Required to submit proposed rule changes to FERC for approval.
  • Challenges: Geographic aggregation, simultaneous retail and wholesale participation, accurate metering and compensation.

Implementation Timelines

  • CAISO: Partial implementation, full by Nov 2024.
  • NYISO: Full implementation by end of 2026.
  • ISO-NE: Energy/ancillary by Nov 2026, capacity by Feb 2026.
  • SPP: Implementation by Q3 2025.
  • PJM: Energy/ancillary by Q1 2026, capacity by Dec 2025.
  • MISO: Phase 1 by June 2027, Phase 2 by 2029-30.

Opportunities for Aggregation

  • Entities Involved: For-profit, non-profit, local governments, and utilities may offer aggregation services.
  • Existing Programs: Participation in current programs (e.g., solar net metering) may influence eligibility.

Additional Information

  • Contact FERC: Office of Public Participation for more details and assistance.