Capacity market participation (FERC Order 2222)

For Trade and Geopolitical Risk teams, Federal Energy Regulatory Commission Order 2222 is not an energy-sector abstraction: it directly affects how distributed energy resource aggregators qualify for, and withdraw from, U.S. capacity markets, with downstream exposure for any firm holding supply-chain or infrastructure positions tied to grid reliability assets. The Federal Energy Regulatory Commission and, at the state level, relevant Independent System Operators operating under FERC jurisdiction are the primary authorities enforcing compliance timelines that most non-utility legal and risk teams have not yet mapped to their counterparty or asset-level obligations. Compliance officers are currently working through whether their entities' contractual relationships with DER aggregators trigger any participation, disclosure, or exit obligations under the Order 2222 tariff frameworks adopted by individual ISOs.