The Federal Energy Regulatory Commission (FERC) on September 17 approved Order 2222 to enable distributed energy resources (DER) to compete in all regional organized wholesale electricity markets. Chairman Neil Chatterjee and Commissioner Rich Glick approved the order with Commissioner James Danly dissenting. Under the order, FERC finds that the current market rules of the Regional Transmission Organizations (RTO) and Independent System Operators (ISO) are creating barriers to the participation of DERs in the markets. The order requires RTOs and ISOs to revise their tariffs to ensure that their market rules facilitate the participation of distributed energy resource aggregations. Small utilities (utilities whose total electric output for the preceding fiscal year did not exceed 4 million MWh) are able to opt-out of the program to avoid overburdening them. NASEO is examining the implications of Order 2222 for states and welcomes State Energy Offices’ viewpoints. We are continuing our review to assess the implications for state vs. Federal jurisdiction.