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FERC Order 2222 Interconnection Checklist v2.1 (Excel)

FERC Order 2222 Interconnection Checklist v2.1 (Excel) is a standardized, spreadsheet-based tool developed to guide stakeholders—such as DER aggregators, interconnection applicants, and utilities—through the technical, procedural, and regulatory requirements for interconnecting distributed energy resource (DER) aggregations under FERC Order No. 2222. It operationalizes the rule’s mandate that RTOs/ISOs remove barriers to DER aggregation by standardizing interconnection processes across jurisdictional boundaries. The checklist serves as both a compliance aid and a collaborative workflow document supporting transparency, consistency, and auditability in interconnection studies and agreements.

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📖 Overview

FERC Order No. 2222, issued in September 2020, requires Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs) to establish rules enabling aggregated distributed energy resources—including rooftop solar, battery storage, electric vehicles, and controllable loads—to participate in wholesale electricity markets as a single, dispatchable entity. The Interconnection Checklist v2.1 (Excel) is a practitioner-facing implementation artifact that translates the order’s regulatory mandates into actionable, phase-gated steps aligned with the interconnection process lifecycle: pre-application scoping, feasibility assessment, system impact study, facility study, and interconnection agreement execution. It incorporates jurisdictional nuances (e.g., differences between CAISO, PJM, MISO, NYISO) while maintaining core harmonization—such as defining aggregation boundary criteria, telemetry and control interface requirements, and cybersecurity compliance (NERC CIP-011, NIST SP 800-53). The Excel format enables dynamic validation (e.g., conditional formatting for missing documentation), embedded hyperlinks to tariff sections and FERC filings, and version-controlled collaboration across engineering, legal, and market operations teams. Version 2.1 specifically enhances traceability to FERC’s July 2023 order on interconnection queue reforms and integrates updated cybersecurity and communications protocol expectations from the 2022 NIST IR 8401 framework for DER interoperability.

📑 Key Components

1 Aggregation Boundary Definition Matrix

2 Interconnection Study Phase Gate Tracker

3 Regulatory Compliance Crosswalk (FERC, NERC, State PUC)

🎯 Applications

✓ Pre-submission gap analysis for DER aggregator interconnection applications
✓ RTO/ISO internal process alignment and staff training
✓ Third-party due diligence for financing or M&A of DER portfolios

📐 Key Formulas

Aggregation Capacity Threshold Validation

SUM(Individual DER Nameplate Ratings) × Aggregation Derating Factor ≤ Interconnection Voltage Level Max Capacity

Verifies whether the proposed DER aggregation complies with the maximum allowable capacity limit at its point of interconnection, applying site-specific derating factors for intermittency, location, and control latency.

Telemetry Latency Budget Allocation

Total Allowable Latency = Control Signal Propagation + Device Response Time + Cybersecurity Processing Overhead ≤ 100 ms (per FERC Order 2222 Annex B)

Calculates end-to-end communication latency budget to ensure real-time dispatch compliance for aggregated DERs participating in regulation or contingency reserves.

🔗 Related Concepts

Distributed Energy Resource Aggregation FERC Order No. 2222 Interconnection Queue Reform Open Automated Demand Response (OpenADR) IEEE 1547-2018

📚 References

FERC Order No. 2222 (September 16, 2020)

NERC CIP-011-4: Cyber Security – Electronic Security Perimeter(s)

NIST IR 8401: Interoperability Framework for Distributed Energy Resources

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