FERC Order 2222: Implementation Is Progressing, but More Work Is Needed from Stakeholders

Since the U.S. Federal Energy Regulatory Commission (FERC) issued Order 2222 in 2020 to better enable aggregations of distributed energy resources (DER) to participate in wholesale electricity markets, the regional transmission organizations (RTOs) and independent system operators (ISOs) that control the wholesale electricity markets in the U.S. have made substantial progress in implementing DER aggregation (DERA) participation. However, in navigating the complexities of FERC's market criteria, each RTO/ISO has refined its market concept in its own way, which presents a challenge for the DER industry to fully understand and adapt to the new DERA participation models.

To make FERC Order 2222 a reality, RTOs/ISOs will need to continue refining their market plans to enhance DERA participation and mitigate any market flaws or grid failures. Distribution utilities (DUs) will need to continue offering attractive compensation mechanisms to DER and DERAs at the retail level to reap the benefits of the injected energy and grid services provided. Additionally, DUs must fully understand their respective RTO/ISO DERA market plans to effectively coordinate with their RTO/ISO regarding resource dispatch, grid congestion, and grid stability issues. DER developers and aggregators must also understand wholesale electricity market rules and DERA participation options to maximize DERA viability and grow business across the U.S.

This Guidehouse Research report provides an update on the six RTO/ISO DERA market participation models, including implementation timelines and explanations of the key market concepts and rules for each RTO/ISO and how they conform with FERC Order 2222's directives. The report concludes by discussing the potential for DERA market participation growth in the U.S. and offering recommendations for the key DERA stakeholders.