FERC Order 2222 — how is it affecting your audits?

Started by Former Member — 2 months ago — 54 views
FERC 2222 is still working its way through state implementation. For most commercial auditors the practical impact is indirect — through demand response program changes.
FERC 2222 is finally rolling into most RTOs. Seeing any of this on bills yet? I'm starting to notice new line items on PJM territory accounts that I can't reconcile to any tariff I've seen. Anyone digging into the DER aggregation charges?
Started seeing "DER Integration Charge" on a handful of PJM accounts in February. None of the state commissions have published guidance yet. My approach is flag-and-hold — document the charges, don't dispute yet, revisit once the PSCs publish their reconciliation rules. Most will retroactively adjust.