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New FERC Aggregation Order for Distributed Energy Resources: Qualifications, ISOs/RTOs Directives, State-Opt Outs

Recording of a 90-minute premium CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Thursday, December 10, 2020

Recorded event now available

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This CLE course will guide energy sector attorneys on the new FERC order regarding the aggregation of distributed energy resources. The panel will discuss next steps for participants, qualifications, new directives for independent system operators and regional transmission organizations (ISOs/RTOs), state-opt outs, and other key items that must be considered to benefit from the new aggregation order for energy markets.


On Sept. 17, 2020, FERC issued Order No. 2222 to further reform wholesale electric markets by removing barriers to the participation of distributed energy resource (DER) aggregations in the capacity, energy, and ancillary service markets operated by ISOs/RTOs. Energy sector counsel and participants must grasp a complete understanding of how this order may have an impact on market rules and potential opportunities for DER aggregators.

The rule applies to various DERs, including electric storage resources, distributed generation, energy efficiency, thermal storage, electric vehicles, and other resources. However, the rule also has strict qualification requirements for participants, outlines new directives for ISOs/RTOs, and provides certain opt-outs for states.

Listen as our panel discusses the impact of FERC Order No. 2222, key requirements, and potential challenges, as well as outlines next steps for participants seeking to benefit from the new aggregation order for energy markets.



  1. The value of DERs to the electric grid
  2. Evaluating current pricing approaches
    1. Net metering
    2. Fixed charges
    3. Net metering caps
  3. New FERC aggregation order
    1. Participant requirements
    2. New directives for ISOs/RTOs
    3. State opt-out
  4. Next steps and other considerations for participants


The panel will review these and other key issues:

  • What is the value of DERs?
  • What is the impact of FERC Order No. 2222 for electric utilities?
  • What are the requirements for participants under the new FERC aggregation order for DERs?
  • What new directives must be followed by ISOs/RTOs?
  • What options are available for states under the new order?
  • What other items must be considered to benefit from the new aggregation order for energy markets?


McAllister, Levi
Levi McAllister

Morgan, Lewis & Bockius

Mr. McAllister advises clients subject to regulatory oversight in the natural gas, crude oil, natural gas liquids, and...  |  Read More

Urban, Blake
Blake Urban

Senior Counsel

Mr. Urban advises clients on regulatory matters in the electric industry before federal and state regulatory agencies...  |  Read More

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