In 2016, FERC responded to comments from AEE and others calling for the Commission to expand its initial inquiry into barriers facing energy storage to examine a wider array of advanced energy technologies that cannot fully compete under current market rules by including distributed energy resources like rooftop solar when they are aggregated for market participation.

AEE supported this expansion of the rule to encompass aggregated distributed energy resources (DER) and encouraged FERC to continue to pursue breaking down of barriers to market competition in a comprehensive way.

In November 2016, FERC released a Notice of Proposed Rulemaking (NOPR) AEE filed comments in which it expressed support for the general direction of the NOPR, and offered suggestions for improvements to achieve the Commission’s objective of removing unjust, unreasonable, and unduly discriminatory barriers to participation in the wholesale markets.