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.
Roundtable Meetings
A series of roundtable meetings that focused on specific topics were held monthly from June through November. These meetings were typically held in-person at the Indiana Government Center South (IGCS) building in the conference rooms indicated below.
- November 9, 2023: 9:30 a.m. to 12:00 p.m. - Indiana Government Center South, 302 W. Washington Street, Indianapolis (Conference Room B)
The discussion focused on possible next steps.
Notes from the meeting: Word doc | PDF
Comments from CPower | PDF
- October 12, 2023: 9:30 a.m. to 12:00 p.m. - Indiana Government Center South, 302 W. Washington Street, Indianapolis (Conference Room B)
The discussion focused on the following topics:- Cost recovery: For hardware/software/metering/facility upgrades/administration.
- 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?
- Distribution wheeling charges: An amount charged by one electrical system to transmit the energy of, and for, another system or systems.”
Notes from the meeting: Word doc | PDF
Comments from Voltus | PDF
- September 14, 2023: 1:30 p.m. to 4:00 p.m. (Hybrid meeting)
The meeting included presentations from DER aggregators (Voltus and CPower), Collaborative Utility Solutions, and Octopus Energy Group. Click here to view the agenda and here to watch a YouTube recording of the meeting.
Presentations:
- August 16, 2023: 9:30 a.m. to 12:00 p.m. - Indiana Government Center South, 302 W. Washington Street, Indianapolis (Conference Room A)
The discussion focused on the implications and operational considerations/concerns regarding the operation of DER aggregations on/across distribution systems.
Notes from the meeting: Word doc | PDF
Revised notes from the meeting: Word doc | PDF
Resource referenced during the meeting:- I&M Engineering Impacts from Distributed Energy Resources Aggregation | PDF
- July 13, 2023: 9:30 a.m. to 12:00 p.m. - Indiana Government Center South, 302 W. Washington Street, Indianapolis (Conference Room B)
The discussion focused on state-level registration process and public utility status.
Notes from the meeting: Word doc | PDF
Resources referenced during the meeting:
- June 8, 2023: 9:30 a.m. to 12:00 p.m.- Indiana Government Center South, 302 W. Washington Street, Indianapolis (Conference Room C)
The discussion focused on reviewing the existing interconnection rule.
Notes from the meeting: Word doc | PDF
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
Stakeholder Meeting on March 2, 2023
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.
Agenda: PDF
Watch live at the link here
Presentations: Voltus | Solar United Neighbors | Indiana Michigan Power | Citizens Action Coalition | MISO Indiana Utilities
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
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.