HMS Legal Blog

RULE 2222: A Good Start in the FERC’s Efforts to Bring Renewables into Wholesale Markets


The purpose of this article is to unpack one of the most recent FERC Orders on alternative energy and discuss the new market opportunities, if any, that it will open to an industry struggling to find a path for broader customer engagement on renewables and demand reduction products.  The Federal Energy Regulatory Commission (“FERC”) latest order has changed the rules for who can participate in the wholesale power markets.  This latest FERC move will allow renewable energy producers as small as homeowners with a roof covered in solar panels or an electric vehicle in the garage, to participate in wholesale markets through aggregation with other smaller scale resources, despite being located on the distribution system. Under prior rules, most of these resources were too small to participate in the wholesale markets.  However, with its Order No. 2222, issued September 18, 2020, FERC changed the opportunities for these smaller users by permitting distributed energy resources (“DER”) to participate as part of an aggregation in wholesale markets operated by Regional Transmission Organizations (“RTO”) and Independent System Operators (“ISO”).  Despite, efforts to alter Order 2222 by Order 2222-A on March 18, 2021, and Order 2222-B on June 17, 2021, Order 2222 remains largely unchanged. 

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