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Developing and Defending an ISO’s Compliance with FERC’s Order No. 2222

Wright & Talisman assisted ISO New England, Inc. (ISO-NE) in its filings to comply with the Federal Energy Regulatory Commission’s (FERC) Order No. 2222, which addresses the participation of distributed energy resource aggregations in the capacity, energy, and ancillary service markets operated by regional transmission organizations and independent system operators.  We worked with ISO-NE to revise its tariff provisions for the Forward Capacity Market to accommodate distributed energy resource participation. FERC largely adopted these revisions in its initial order. We then assisted ISO-NE in requesting rehearing of certain aspects of FERC’s order that would impede ISO-NE’s proposed compliance plan. FERC’s initial rehearing order resolved all issues raised in ISO-NE’s favor.