Are We There Yet? Getting Distributed Energy Resources to Markets

Commenters and advocates hailed Federal Energy Regulatory Commission (FERC) Order No. 841 and Order No. 2222 as landmark orders in the transition to a clean energy future when they were issued in 2018 and last September, respectively. These orders aim to open organized wholesale markets to new technologies. Order No. 841 does this for energy storage resources, while Order No. 2222 does it for distributed energy resources. Of course, whether the orders live up to their billing as transformative and revolutionary efforts to demolish barriers to market participation will turn on whether the required details and intricacies can be mastered during implementation.Former FERC Chairman Norman Bay said, together, Order Nos. 841 and 2222 “have the potential to be truly landmark orders as the energy transition accelerates.” But, as with nearly all regulations, the effectiveness of Order Nos. 841 and 2222 will be determined by how faithfully and timely the regulated parties - here Regional Transmission Organizations/Independent System Operators (RTOs/ISOs) - implement FERC’s vision for the orders. This issue brief rounds up RTO/ISO efforts to implement Order Nos. 841 and 2222, showing where there has been progress, where there have been delays, and what is at stake