Distributed Generation

A September 17, 2020 Final Rule adopted by the Federal Energy Regulatory Commission (“Commission”) removes barriers to the participation of distributed energy resource aggregators in Regional Transmission Organization (“RTO”) and Independent System Operator (“ISO”) markets.[1]  The Commission’s modified regulations[2] require each RTO/ISO to revise its tariff to ensure that its market rules facilitate the participation of distributed energy resource aggregators.  Order No. 2222 is a positive development for distributed energy resources that would like to participate in wholesale electric markets but are unable to do so, and should encourage greater renewable energy resource development in the coming years.  However, the scope and implementation of each RTO’s/ISO’s participation model remains to be seen: distributed energy resources will need to keep an eye on RTOs’/ISOs’ proposed tariff revisions.  Moreover, maximizing the opportunity for distributed energy resources to contribute to markets will be affected by whether the Commission continues to reform Commission-jurisdictional markets to broaden participation of emerging technologies as it did in Order No. 2222, or adopt measures that bolster the viability of fossil and nuclear resources at the expense of emerging technologies as it has done in other proceedings.
Continue Reading Federal Energy Regulatory Commission Gives Distributed Energy Resource Aggregators a Boost; Implementation Will Present Challenges