FERC Order 2222 and flexibility markets

Distributed energy resources (DERs) are spreading rapidly across the US grid. Managing this growing resource pool is one of the challenges facing utilities today.

FERC Order 2222 exists to help, but nearly five years after its introduction, implementation remains slow. This guide explains what it’s all about, and what utilities can do to move forward.

Key facts: FERC Order 2222 at a glance

Issued by	Federal Energy Regulatory Commission (FERC)
Year issued	2020
Minimum aggregation size	100 kW
Who it affects	RTOs ISOs DER aggregators Utilities
Core requirement	DER aggregators must be able to participate in wholesale energy markets
Main challenges	Barriers to entry, metering, coordination, and simultaneous participation rules

Each ISO/RTO sets its own implementation timeline and participation rules to achieve the order.

What is FERC Order 2222?

The Federal Energy Regulatory Commission (FERC) is the federal body responsible for regulating transmission and wholesale electricity markets in the US. It has jurisdiction over regional transmission operators (RTOs) and independent system operators (ISOs).

FERC Order 2222 mandates that DER aggregators of 100 kW or more are able to participate in wholesale electricity markets.

This means that individual asset owners such as a homeowner with solar panels or a business with a battery don’t participate directly. Instead, they go through an aggregator, which pools multiple assets into a resource large enough to operate in those markets.

The order sets out how this participation should work, including rules around safety, compensation, and coordination between federal, state, and local levels.

The UK has already enacted something similar under code modification P415, which allows smaller-scale flexible resources to access the wholesale market and get paid for demand turn-down activity.

The US equivalent is larger in scope, but the underlying principle, i.e. giving distributed flexibility a route into markets, is the same.

What does FERC Order 2222 aim to achieve?

Wholesale and RTO markets were designed for traditional, large-scale generators (power plants, gas peakers, etc). They were not built with small, distributed resources in mind.

FERC Order 2222 addresses the mismatch. Its goals are to:

Unlock a growing resource pool

The order recognises DER capacity as an asset. By enabling aggregators to bring resources into wholesale markets, operators gain access to flexible capacity located where it is often most needed.

Lower the cost of energy

Greater participation by flexible DERs increases competition in wholesale markets, which can lead to more efficient pricing and lower overall energy costs.

Improve grid reliability

Flexible DERs can respond to grid conditions quickly and at a local level. Coordinating them effectively through wholesale markets improves resilience, particularly during severe weather events.

Why has implementation been slow?

Three factors in particular explain why this has taken longer than anticipated.

1. Regulatory and stakeholder process drag

Each RTO and ISO has had to file its own compliance plan and then iterate on it through a stakeholder process involving utilities, states, aggregators, and consumer advocates.

These processes address reliability concerns, resolve jurisdictional tensions between FERC and state commissions, and negotiate cost recovery and risk allocation – but the whole process can take time.

2. The review and coordination burden

The order gives utilities the right to review DER aggregations for reliability before they can participate in wholesale markets. In principle this is a sensible safeguard but most utilities don’t yet have the systems to do it efficiently.

Without a clear map of where DERs are located and what they are already committed to, the review process can become a bottleneck that compounds the stakeholder and ecosystem delays.

3. The DER ecosystem is still maturing

In many regions, the underlying DER base and the utility processes needed to support them are still developing.

Even where rules exist on paper, actual market participation lags because business models are still being proven, and utilities and aggregators are still piloting and learning how to operate under the new framework.

What are the main barriers to DER participation?

For utility operators working to implement FERC Order 2222, there are barriers to navigate:

Size

Minimum size requirements

Most wholesale markets have minimum capacity thresholds to participate. While the order sets 100 kW as the aggregation minimum, individual market rules vary, and assembling enough DER capacity to qualify consistently can be challenging.

Metering

Telemetry and metering requirements

Participation in wholesale markets requires real-time data. DERs need to be monitored and measured accurately so that RTOs know how much flexibility has been delivered and can compensate accordingly. Many smaller assets do not yet have the communication infrastructure required.

Location

Locational aggregation rules

Whether aggregation is permitted at the nodal level or across broader zones has implications for who can participate and where.

Coordination

Simultaneous participation rules

DERs enrolled in utility demand response programs or community solar schemes may also want to participate in wholesale markets through an aggregator. Coordinating these overlapping relationships and ensuring the same flexibility is not compensated twice requires clear rules and careful data management.

Visibility

Visibility and data flows

Under FERC Order 2222, utilities have a formal right to review DER aggregations for reliability. But without a clear picture of where assets are located and what they are already committed to, that review becomes a slow, manual process. Utilities often lack real-time visibility over which markets their DERs are active in and what they are doing at any given time.

Discover how ElectronCompass helps utilities reveal hidden DER capacity →

How can the right technology help?

Two types of tool can help support this mandate: one for market coordination, one for grid visibility.

Lowering barriers to entry

Some flexibility market platforms can run multiple market types at once, tailored to different use cases. This gives aggregators more routes to participate, and utilities more tools to procure the flexibility they need.

Gaining visibility over DER capacity

Before any market coordination can happen, utilities need to know where their DERs are and what they are already committed to. Visibility tools can fill in that blind spot, making approval processes faster and giving utility planners the confidence to act.

Managing multi-market conflicts

The challenge then becomes what happens when the same asset wants to serve multiple markets at once. A battery bidding into an ISO wholesale market under FERC Order 2222 might also be needed by the local utility to manage a peak constraint.

A market platform can help ensure that a bid into a wholesale market doesn’t compromise local grid stability, and can automate the “double-counting” checks that currently keep regulatory lawyers up at night.

Generating insights

Participation data helps offer up some actionable intelligence: how much flexibility is being delivered, what it costs, what its grid impact is. These insights allow operators to refine market design over time and build the evidence base that supports wider adoption.

Electron’s approach

FERC 2222 is a mandate, but Electron makes it manageable. Implementing it requires solving two distinct problems, and Electron has built tools for both.

The first is visibility.

Utilities can’t approve the FERC 2222 aggregations for reliability if they don’t know where the assets are or what they are already committed to. ElectronCompass addresses this, giving utility planners way to detect hidden DER capacity and turn a manual review process into something that can scale.

The second is coordination.

ElectronConnect then can act as the bridge between the RTO’s wholesale market needs and the utility’s local grid constraints. It’s the flexibility market software that supports utilities and grid operators to design, run, and manage flexibility markets at scale, and handles the technical complexity of publishing requirements, collecting bids, dispatch, and settlement.

That coordination layer is what makes FERC Order 2222 participation more practically workable.

FAQs

What is the minimum size to participate under FERC Order 2222?

DER aggregators must reach at least 100 kW to participate in wholesale markets under the order. Individual market rules within specific RTOs may set higher thresholds.

Do individual DER owners participate directly?

No. Individual asset owners such as homeowners with solar panels participate through an aggregator, who pools multiple assets to meet market thresholds.

What happens if a DER is enrolled in a utility demand response program and also wants to participate in wholesale markets?

Simultaneous participation is possible but governed by strict rules designed to prevent the same flexibility being compensated twice. Coordination between the utility program and the wholesale market aggregator is required.

What is the UK equivalent of FERC Order 2222?

Code modification P415 in the UK allows smaller-scale flexible resources to access the wholesale market and receive payment for demand turn-down activity. It provides a useful reference point for how distributed flexibility can be integrated into wholesale markets in practice.

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