Order No. 2222, issued on September 17, 2020 by the Federal Energy Regulatory Commission, was created with the intent usher ISOs/RTOS in the electric grid in the electric markets “by removing the barriers preventing distributed energy resources (DERs) from competing on a level playing field in the organized capacity, energy and ancillary services markets run by regional grid operators,” according to FERC.

As posted on the ISONE website, “ISO New England has enabled thousands of megawatts of DERs to participate in its markets through development of multiple participation options. However, as technologies advance and small DERs proliferate, some of these resources may be unable to meet minimum size and performance requirements. Order No. 2222 reasons that through aggregation, more of these resources might meet those requirements and be able to participate in wholesale markets alongside traditional resources to provide flexible services to the power grid.”

ISONE filed a motion to extend the compliance filing deadline to today, February 2, 2022 and was granted the motion in May 2021.

As ISONE states, Order No. 2222 has eleven key compliance directives:

    1. Allow DERAs to participate directly in RTO/ISO markets and establish DER aggregators as a type of market participant; DERAs may include more than one technology type, i.e. heterogeneous aggregations
    2. Allow DER aggregators to register DERAs under one or more participation models that accommodate the physical and operational characteristics of the DERA
    3. Address size requirements for DERAs and individual DERs
    4. Address locational requirements for DERAs
    5. Address distribution factors and bidding parameters for DERAs
    6. Address information and data requirements for DERAs
    7. Address metering and telemetry requirements for DERAs
    8. Establish market rules on coordination between the RTO/ISO, DER aggregator, distribution utility, and Relevant Electric Retail Regulatory Authorities (RERRAs)
    9. Address modifications to the list of DERs in a DERA
    10. Address market participation agreements for DER aggregators
    11. Implement opt-in provision for distribution companies with ≤ 4 million MWh of annual sales


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