Order 2222 Filing Furthers DER Market Participation


PJM filed a comprehensive proposal Feb. 1 outlining how it will comply with Order 2222, the Federal Energy Regulatory Commission’s directive for power system operators to create market rules enabling the participation of distributed energy resource aggregations in the wholesale markets.

The filing (PDF) is the product of extensive engagement with stakeholders, who have worked with PJM to develop an approach that balances both the needs of distributed energy resource (DER) aggregators to participate in PJM’s markets on a level playing field with other resource types, and the rights of relevant electric retail regulatory authorities and distribution utilities to ensure safe and reliable operations on the distribution system.

DER aggregation participation in PJM charters new territory in several areas, including interactions between distribution and transmission systems, emerging technology integration, grid modernization, and operational flexibility.

The framework being put forward is a foundation for DER aggregation participation in wholesale markets that will evolve over time as experience is gained by all parties.

Some key elements of the compliance approach include:

  • A new market participation model called the DER Aggregator Participation Model
  • Pre-registration coordination activities between DER aggregators and distribution utilities to  determine locational and data components needed for the DER aggregators’ registration with PJM
  • A 60-day review period whereby distribution utilities can, among other things, analyze a proposed registration for distribution system reliability impacts
  • Locational requirements that support reliable operations and energy price formation, and are as geographically broad as technically feasible
  • Enabling of retail and wholesale participation while at the same time preventing double counting of the same product
  • Balanced metering and telemetry requirements
  • A coordination framework that balances market access with safe and reliable distribution system operations

The filing requests the following dates:

  • An effective date of Feb. 2, 2026, for the Tariff, Operating Agreement and Reliability Assurance Agreement revisions
  • An effective date of July 1, 2023, for a limited subset of revisions

An extension of the standard 21-day comment period – from Feb. 22 to April 1, 2022 – to provide PJM stakeholders additional time to develop their responsive pleadings