Capacity market participation (FERC Order 2222)
Defense and government contractors operating distributed energy assets, microgrids, or on-site generation now face a direct compliance question under Federal Energy Regulatory Commission Order 2222: whether their aggregated resources qualify for, or must be disclosed in connection with, regional capacity market participation. The Federal Energy Regulatory Commission opened that door in 2020, and regional transmission organizations including PJM Interconnection are still working through implementation tariffs that directly affect how contractors with energy resilience infrastructure interact with wholesale markets. Contracting officers and general counsel are reviewing facility energy agreements now, before RTO compliance windows close.
Watch
- PJM Order 2222 compliance filing deadlines for distributed energy resource aggregators
- FERC notice of proposed rulemaking activity on DER aggregation in defense-adjacent microgrids
- DoD facility energy resilience requirements intersecting with wholesale market participation rules
- State utility commission orders that restrict or condition DER aggregation in FERC-jurisdictional markets
Recent material activity in Defense & Government Contracting
Active monitoring in place across Defense & Government Contracting. Material developments related to capacity market participation (ferc order 2222) will appear here as they are published.