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Implementation re: FERC Order 2222

The Indiana Utility Regulatory Commission (IURC or Commission) is beginning the stakeholder process 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, 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

December 1, 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 Due Feb. 2, 2023

Following the educational meeting on Dec. 1, 2022, the Commission invites stakeholder comments on any issues that you think need 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.). It’s important to note that the goal of this process is compliance with the legislative mandate in Ind. Code ยง 8-1-40.1-4. Commission staff offers an initial set of topics for consideration; however, we do not intend this to be an exhaustive list and we want and need your input to fully vet stakeholder concerns during this process. 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.

Please submit all comments to by Feb. 2, 2023.

Stakeholder Meeting on March 2, 2023

Our next meeting is scheduled for March 2, 2023, with a similar format as our December 1st meeting, including the opportunity for both in person and online participation via YouTube.  For this meeting, we are inviting presentations from distributed energy resources, DER aggregators, consumer advocates, electric utilities, and any others who would like to present regarding FERC Order 2222 and state level implementation of that order.  If you are interested in making a presentation, please email by Feb. 2, 2023.