In September 2020, the US Federal Energy Regulatory Commission (FERC) released Order No. 2222, which significantly changed the market structure of energy grids. Prior to this legislation, local system operators typically enforced minimum capacity and performance requirements on suppliers looking to sell energy in wholesale markets to the exclusion of DERs. In some cases, DERs were allowed to sell electricity via contracts called power purchase agreements (PPAs) , but most utilities negotiated with DERs directly (outside the wholesale market structure) and followed a practice of paying DERs at their avoided cost. The avoided cost typically ranges between 40 and 60 USD/MWh (varying regionally) and is also significantly less than average wholesale prices . This structure proved insufficient to cover the costs of biogas production, and meant few DERs could operate within this framework . A detailed discussion on the FERC-2222 order is provided in the supplemental information. Under FERC-2222, system operators can still mandate minimum participation requirements, but must allow DERs and other small-scale renewable energy producers (including bioenergy-producing farms) to aggregate to meet these requirements . Aggregation provides an efficient way to organize DERs in an energy market. The aggregated DER bids into the wholesale market on behalf of its member DERs, which then individually commit electricity to the aggregate supply bid .