August 5, 2023

FERC Order No. 2222 and Considerations for Distributed Wind


The Federal Energy Regulatory Commission (FERC) issued Order No. 2222 in October 2020. The rule directs Regional Transmission Organizations and Independent System Operators (ISOs) to amend their tariffs and participation models to accommodate heterogeneous distributed energy resource (DER) aggregations in the wholesale energy markets that they operate, including capacity, energy, and ancillary service markets. The Commission issued the rule to better capture the benefits provided by DERs deployed in the United States, whose use has been expanding rapidly. The Commission defines DERs as “any resource located on the distribution system, any subsystem thereof or behind a customer meter,” including but not limited to “electric storage resources, distributed generation, demand response, energy efficiency, thermal storage, and electric vehicles and their supply equipment.” The rule aims to increase DER participation in wholesale markets by allowing the creation of DER aggregations, in which multiple DERs that are too small to meet minimum capacity requirements for wholesale markets individually would be able to participate in markets as a single unit. As of June 20, 2023, all ISOs have filed initial compliance plans and a number have begun implementation. Compliance dates range from 2024 to 2029, with Midcontinent ISO having the latest date of compliance proposed for 2029. Southwest Power Pool still has an outstanding date, having no final order yet from FERC, but a target date of the third quarter of calendar year 2025. The rule, which is technology agnostic and requires ISOs to create participation plans that accommodate different DERs, provides an opportunity for distributed wind market expansion. In addition, distributed wind can bring benefits to heterogenous DER aggregations. These benefits include resource diversity (i.e., a complementary generation profile to other types of distributed generation), its small footprint and ability to be co-located with load, and its potential to provide frequency response, voltage support, and black start services, among other ancillary services. This report provides a status update on FERC Order No. 2222, the current state of ISO compliance, and information relevant to the distributed wind industry as DER aggregators and other stakeholders expand their participation to wholesale energy markets.

Published: August 5, 2023


Tapio R.M., and A.C. Orrell. 2023. FERC Order No. 2222 and Considerations for Distributed Wind Richland, WA: Pacific Northwest National Laboratory.

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