Implementation re: FERC Order 2222
The Indiana Utility Regulatory Commission (IURC or Commission) is working with stakeholders on its implementation regarding Federal Energy Regulatory Commission (FERC) Order 2222. Information about stakeholder meetings and comment periods can be found below. All documents, comments, and information regarding this stakeholder process, including the YouTube links to view the stakeholder meetings that were live-streamed, will also be posted below.
All comments, as well as requests to be added to the email distribution list for this stakeholder process, should be sent to URCComments@urc.IN.gov.
Stakeholder Meetings
IURC staff is continuing the stakeholder process on the implementation regarding FERC’s Order 2222 in Indiana. In addition to conducting a series of roundtable meetings in 2023, the Commission hosted two informal public stakeholder meetings in June 2024 and May 2025.
- FERC Order 2222 Stakeholder Meeting
May 29, 2025 | 9:00 a.m. to 12:00 p.m. ET
Indiana Government Center South (302 W. Washington St.) in Conference Room C
Details: On May 29, 2025, IURC staff hosted an informal public stakeholder meeting to discuss next steps and seek input regarding rules that may be needed for a registration and study process of DER aggregations participating in wholesale markets via distribution systems in Indiana. This was an opportunity for stakeholders to identify the information needed and processes necessary to implement DER aggregations in Indiana. View the May 29 meeting agenda.
- FERC Order 2222 Stakeholder Meeting (hybrid)
June 11, 2024 | 9:30 a.m. to 11:30 a.m. ET
PNC Building, IURC Judicial Courtroom 222 (101 W. Washington St.) | Microsoft Teams
Details: On June 11, 2024, IURC staff hosted an informal (hybrid) public stakeholder meeting for a first read and discussion regarding the strawman draft amendments to Indiana’s customer-generator interconnection rule, 170 IAC 4-4.3. Learn more about the rulemaking by visiting the interconnection rule website. Comment Period: The deadline to submit comments on the strawman draft proposed rule was July 12, 2024.
Stakeholder Comments
Following the May 29 stakeholder meeting, the Commission held two public comment periods: The first sought feedback on the topics discussed during the stakeholder meeting, while the second invited responses to the initial round of comments, in particular those addressing DER aggregator registration with the IURC and DER aggregation registration with the relevant utility (e.g. the comments submitted by I&M Power and the Public Interest Organizations below).
First Comment Period
The IURC received the below comments following the May 29 stakeholder meeting:
- Advanced Energy United | PDF
- Hoosier Environmental Council | PDF
- Indiana Electric Cooperatives | PDF
- Indiana Michigan (I&M) Power | PDF
- Indiana Rural Electric Membership Cooperatives (REMCs) | PDF
- NIPSCO | PDF
- Public Interest Organizations: Citizens Action Coalition of Indiana, Solar United Neighbors, Environmental Law & Policy Center, and Vote Solar | PDF
Reply Comment Period
The IURC received the following reply comments in response to the comments received during the initial round:
2023 Roundtable Meetings
A series of roundtable meetings that focused on specific topics were held monthly from June through November in 2023. These meetings were typically held in-person at the Indiana Government Center South (IGCS) building in the conference rooms indicated below.
- Roundtable Meeting 6
November 9, 2023 | 9:30 a.m. to 12:00 p.m. ET
Indiana Government Center South (302 W. Washington St.) in Conference Room B
Details: The discussion focused on possible next steps.
- Roundtable Meeting 5
October 12, 2023 | 9:30 a.m. to 12:00 p.m. ET
Indiana Government Center South (302 W. Washington St.) in Conference Room B
Details: The discussion focused on the following topics: (1) Cost recovery: For hardware/software/metering/facility upgrades/administration. (2) Cost allocation: To subsidize or not to subsidize? What are the benefits for non-participants? Are the benefits quantifiable? What would the benefit metrics be? (3) Distribution wheeling charges: An amount charged by one electrical system to transmit the energy of, and for, another system or systems.
- Roundtable Meeting 4
September 14, 2023 | 1:30 p.m. to 4:00 p.m. ET
Hybrid meeting
Details: The meeting included presentations from DER aggregators (Voltus and CPower), Collaborative Utility Solutions, and Octopus Energy Group. View the September 14 agenda or watch a YouTube recording from the meeting.
Presentations:
- Roundtable Meeting 3
August 16, 2023 | 9:30 a.m. to 12:00 p.m. ET
Indiana Government Center South (302 W. Washington St.) in Conference Room A
Details: The discussion focused on the implications and operational considerations/concerns regarding the operation of DER aggregations on/across distribution systems. Resources referenced during the meeting:- I&M Engineering Impacts from Distributed Energy Resources Aggregation | PDF
- Roundtable Meeting 2
July 13, 2023 | 9:30 a.m. to 12:00 p.m. ET
Indiana Government Center South (302 W. Washington St.) in Conference Room B
Details: The discussion focused on state-level registration process and public utility status. Resources referenced during the meeting:
2023 Stakeholder Meeting
The meeting on March 2, 2023, had a similar format as our December 1st meeting. The meeting started at 10:00 a.m. EST and took place both in person (in IURC Judicial Courtrooms 222 and 224) and virtually on YouTube (link below). The meeting featured presentations from Voltus, Solar United Neighbors, Indiana Michigan Power, Citizens Action Coalition, and the MISO Indiana Utilities. View the March 2 agenda or watch a YouTube recording from the meeting.
Presentations: Voltus | Solar United Neighbors | Indiana Michigan Power | Citizens Action Coalition | MISO Indiana Utilities
Comments received regarding the March 2 meeting
- Armada Power | PDF
- CPower Energy Management | PDF
- Indiana Investor-owned Utilities (Duke Energy Indiana, LLC, Indiana Michigan Power Company, AES Indiana, Northern Indiana Public Service Company, and CenterPoint Energy Indiana South) | PDF
- Public Interest Organizations (Solar United Neighbors, Citizens Action Coalition, IndianaDG, Solarize Indiana, and Indiana Beyond Coal) | PDF
2022 Educational Meeting
On Dec. 1, 2022, the IURC held an educational meeting to start the stakeholder process on IURC implementation regarding FERC Order 2222. The meeting started at 1:30 p.m. EST and took place both in-person (in IURC Judicial Courtrooms 222 and 224) and virtually. The meeting featured presentations from the FERC, the Midcontinent Independent System Operator (MISO), and the PJM Interconnection (PJM).
This first meeting set the stage and provided a high-level overview of FERC’s Order 2222, as well as the compliance actions underway at both MISO and PJM.
Stakeholder Comments
Following the educational meeting on Dec. 1, 2022, the Commission invited stakeholder comments on issues to be considered as part of this stakeholder process and how those issues should be discussed and vetted (for example, additional meetings, rulemaking(s), IURC formal investigation, etc.). Areas of discussion could include:
- The appropriate or preferred process or processes to utilize in the development of rules implementing FERC’s Order 2222 (informal, formal rulemaking, and/or formal investigation).
- Interconnection of component DERs to the distribution system.
- Adjudication of (pre-registration/aggregation registration) disputes.
- Operational oversight and control of DERs.
- Distribution utility overrides of DERs to maintain reliability, and disputes arising therefrom.
- Cost allocations (issues re: technical review costs/upgrades/needed technology/considerations of subsidizations, etc.).
- Dual participation (retail and wholesale participation) and double-counting concerns or challenges.
- State vs. Federal jurisdictional issues.
- DER aggregators as “public utilities”.
- IEEE 1547-2018 standardization.
- Coordination among RTO/utility/aggregator/IURC.
Comments received regarding the December 1 meeting
- Indiana Electric Cooperatives | PDF
- Indiana Michigan Power (I&M) | PDF
- MISO Indiana Utilities (Duke Energy Indiana, AES Indiana, NIPSCO, CenterPoint Energy Indiana South) | PDF
- Public Interest Organizations (Solar United Neighbors, Citizens Action Coalition, IndianaDG, Solarize Indiana, Indiana Beyond Coal) | PDF