Engagement Guidance

Engaging in Wholesale Energy Markets

Applicability:

Most relevant for local governments located within one of the country’s seven ISO or RTO regions. In other areas, wholesale market structures may not apply directly, but market outcomes can still influence utility costs and project economics.

What?

Wholesale electricity markets in the United States are overseen and governed by nonprofit entities—known as independent system operators (ISOs) or regional transmission organizations (RTOs)—that manage market operations, transmission planning, and system reliability. Most of these markets are regulated at the federal level by the Federal Energy Regulatory Commission (FERC), which reviews and approves market rules and major changes. The only exception is ERCOT, because the market operates almost entirely in Texas and avoids the interstate commerce regulations mandated by the Federal Power Act of 1935.

Local governments can engage with their local ISO/RTO or participate in FERC processes to provide input on market rules and operating procedures that affect renewable energy deployment and system operations.

Why?

For local governments situated within the seven regions of the country where organized wholesale energy markets exist, market rules, operating procedures, and planning processes can impact project costs, procurement options, and deployment timelines, even if local governments are not direct market participants. For example, ISOs/RTOs oversee how electric transmission is built, which may be needed to transport electricity from resource-rich areas to population centers. They also determine how and whether clean technologies are compensated for the services they provide to maintain grid reliability and stability.

In some cases, decisions on these issues are brought before FERC, which can require ISO/RTOs (except ERCOT) to implement changes or revisit an issue. By participating in these processes, local governments can help ensure that regional planning and market structures reflect local needs and priorities.

How?

ISOs and RTOs are membership organizations, and local governments can become involved in their stakeholder processes as either voting or non-voting members. Local governments may also engage in FERC proceedings in which changes to rules or procedures are reviewed. There are also informal pathways for engagement, such as attending public meetings hosted by ISOs, RTOs, or FERC; having direct conversations with ISO/RTO staff; and submitting public comments on relevant issues.

Local governments often engage in wholesale market processes in coordination with others. This may include working with peer cities, regional coalitions, utilities, or other large customers to share expertise, align priorities, and provide coordinated input.

Early engagement before key decisions or filings are finalized can be particularly important, as wholesale market processes often follow formal timelines and notice periods that affect when input can be considered.

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