These slides present new research from WRI on ways that local governments can benefit from DER aggregation opportunities enabled by FERC Order No. 2222. Presenters highlight key actions local governments can take to leverage DER aggregations to advance their clean energy and climate goals.

1. HOW LOCAL GOVERNMENTS
CAN BENEFIT FROM FERC
ORDER NO. 2222
August 18, 2022

2. AGENDA
1:00 – 1:10pm Overview of Project Objectives
1:10 – 1:25pm Overview of DERs, FERC Order 2222, and Paper Findings
1:25 – 1:55pm Panelist Q&A
1:55 – 2:00pm Closing Remarks

3. REMINDERS
Please use the Q&A feature to ask any questions, as we have time for dedicated Q&A
at the end of the session.
The slide deck and recording will be shared following the webinar.
If you have any technical issues, send Joseph Womble an email at
joseph.womble@wri.org.

4. SPEAKERS AND PANELISTS
Jennie Chen
Senior Manager, Clean Energy
World Resources Institute
Katrina McLaughlin
Clean Energy Associate
World Resources Institute
Lori Bird
U.S. Energy Director
World Resources Institute
Alex Fisher
Policy Advisor
District of Columbia Department
of Energy and Environment
Emily Orvis
Senior Director of Energy Markets
Voltus, Inc.
Greg Geller
Head of Regulatory Affairs
Enel North America

5. THE CRITICAL ROLE OF LOCAL GOVERNMENTS IN THE
CLEAN ENERGY TRANSITION
• Nearly 200 local governments have
committed to using 100 percent
renewable energy in their communities.
TRANSACTION SIZE (MW) BY ANNOUNCEMENT YEAR
• Local governments have procured
over 18 GW of clean energy since
2015 through various procurement
methods.​
• Engagement in a variety of forums –
including wholesale markets – is critical
to achieving these goals.
Sources: Sierra Club, ACCC Renewables Accelerator
ENGAGEMENT ACTIONS ACROSS FORUMS

6. PROJECT BACKGROUND
Local Government Engagement in Wholesale Electricity Markets
Supported by the U.S. Department of Energy Solar Energy Technologies Office
• Project Goal: Educate local governments on
wholesale market engagement
opportunities and ways to engage in
stakeholder processes to further their clean
energy goals.
• Intended Outcome: More local
governments engage to reduce barriers to
clean energy and take advantage of
opportunities at the wholesale market level.

7. PROJECT ADVISORY COMMITTEE
• Advanced Energy Economy (AEE)
• American Council for an Energy-Efficient Economy (ACEEE)
• City of Alexandria, VA
• City of Cambridge, MA
• Clean Energy Buyers Alliance (CEBA)
• Government of the District of Columbia
• Great Plains Institute (GPI)
• Regulatory Assistance Project (RAP)
• RMI
• Urban Sustainability Directors Network (USDN)
• Other Independent Consultants

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RELATED WRI WORKING PAPERS
Engaging in Wholesale Markets Key RTO Issues for Local Govts

9. BENEFITS OF LOCAL GOVERNMENT
AGGREGATION OF CLEAN ENERGY
RESOURCES: EMERGING OPPORTUNITIES
UNDER FERC ORDER NO. 2222

10. NEW WORKING PAPER ON BENEFITS OF LOCAL GOVERNMENT
AGGREGATION OF CLEAN ENERGY RESOURCES
Access the paper at https://www.wri.org/research/benefits-local-government-aggregation-
clean-energy-resources-emerging-opportunities-ferc-2222
Overview of Key Takeaways:
• Local governments are deploying increasing amounts of DERs
as part of local clean energy and electrification goals
• These DERs may be able to provide grid services and generate
revenues for their owners
• Local government DERs may have characteristics (e.g. large,
predictable or complementary to other loads) that are valuable in
wholesale electricity markets
• FERC Order No. 2222 may reduce barriers to aggregated DER
participation in markets, but regional market rule development is
ongoing and will determine the extent of these revenue
opportunities
• Ownership models will influence these pathways, and early
actions and planning could help local governments maximize the
value of their DERs
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11. DERS AND LOCAL GOVERNMENTS
• Distributed energy resources (DERs) are small-scale resources installed on
the distribution grid, typically behind-the-meter
• Examples include rooftop solar, battery energy storage, electric vehicles,
grid-interactive appliances
• DER landscape increasing, including by local governments who may set city
targets on renewable energy, resiliency, and fleet and building electrification
• Local government use cases may be particularly well-suited for aggregation
due to larger size, predictable usage patterns

12. DER OWNERSHIP MODELS

13. FERC ORDER NO. 2222 AND WHOLESALE MARKETS
• Order No. 2222 establishes a framework for aggregations of DERs to
participate in wholesale electricity markets
• Region-specific rule development is still underway, but most formal
comment opportunities have closed
• Opportunities exist across the various markets (energy, capacity, ancillary
services), but potential market revenues unknown
• Past experience with similar FERC orders for demand response resources
and energy storage resources may be informative

14. FERC RULEMAKING & RTO COMPLIANCE PROCESS
Current status:
- 2 plans conditionally
accepted (CAISO,
NYISO)
- 4 other plans filed
and comment periods
closed

15. KEY ISSUES AND IMPLICATIONS FOR LOCAL
GOVERNMENTS
Issue Potential Implications for Local Governments
Minimum and maximum size thresholds LGs may have larger DERs than e.g. a residential customer,
maximum sizes could limit participation
Locational requirements Limiting to a single node may limit an LG's resources from
participating in a single aggregation, or partnering with other LGs
Metering and telemetry requirements More stringent telemetry and metering on larger aggregations can
drive up costs of participation and may inhibit LG resources from
participating as a single aggregation
Utility and grid operator review of aggregations Registration requirements may delay or preclude participation, LGs
may have less flexible due to budget and administration timelines
Dual participation and multiple revenue
streams
Dual participation rules may force LGs to choose between revenue
streams, constant availability requirements could limit LG
participation to ensure essential services

16. NEXT STEPS FOR LOCAL GOVERNMENTS
• Coordinate internally and identify current and future DER deployment, and
identify any existing retail or wholesale market participation
• Understand existing ownership, contracting, and leasing models
• Research regional rules and identify any early actions or likely technical
requirements
• Evaluate the costs and opportunities of wholesale market participation
• Help shape regional rule development and state policies

17. PANEL: HOW LOCAL GOVERNMENTS CAN BENEFIT
FROM DER AGGREGATION AND FERC ORDER NO. 2222
Jennie Chen
Moderator
Senior Manager, Clean
Energy
World Resources Institute
Alex Fisher
Panelist
Policy Advisor
District of Columbia
Department of Energy
and Environment
Emily Orvis
Panelist
Senior Director of Energy
Markets
Voltus, Inc.
Greg Geller
Panelist
Head of Regulatory Affairs
Enel North America

18. FINAL REMINDERS
• Please download the report to learn more (link in chat).
• Please complete a brief survey seeking feedback on this webinar
(link in chat).
• Thank you for attending the webinar!

19. IMAGE: FLICKR/AARON CROWE
THANK YOU!
For additional information, please reach out to Katrina
McLaughlin (katrina.mclaughlin@wri.org).