​​​​​​​In Order 2222, FERC asserts jurisdiction over DER aggregation transactions within RTO/ISO wholesale markets, including resources in front of and behind the distribution customer meter. A small utility opt-in feature allows almost all distribution cooperatives to maintain local control over the decision to allow aggregator access to their consumer-members. NRECA is seeking to defend this opt-in feature at FERC, which is crucial for electric cooperative operations. Cooperatives are encouraged to be involved in RTO stakeholder discussions and stay up to date on the many market and technical requirements for implementation as they evolve. This advisory provides further details:​