On April 27, FERC issued a notice inviting comments by June 26 on the participation of distributed energy resource aggregations in RTO and ISO markets. An April technical conference on the matter also addressed the broader potential effects of DERs on the bulk power system and included a proposal from FERC on DER aggregation. Some of the many issues considered in this proceeding include:

• Potential operational concerns associated with dual participation of DERs in both wholesale and retail markets, coordination requirements associated with dual participation, implementation requirements such as metering and monitoring (e.g., to prevent double compensation) and the roles of different parties (e.g., regulators, utilities, RTOs/ISOs)
• If utilities are allowed (as proposed in the NOPR) to review and approve individual resources participating in wholesale markets, whether the utilities have a role in determining when participation can begin, and how such a system could or should operate.
• What types of grid architecture could support DER integration and whether the FERC should consider specific requirements for ISOs/RTOs.
• What types of static and dynamic information is currently being provided about aggregated or individual DERs to distribution utilities and to RTOs/ISOs, additional informational needs for distribution utilities, and how such information would be used.
• Whether the participation of aggregations of DERs such as rooftop solar, wind, battery systems, and EVs in the RTO/ISO markets would increase or decrease distribution system variability.