FERC Order 2222 & DER Policy Implementation Bi-Monthly Reports
These bi-monthly reports are a series designed to track and deep dive into DER policy implementation at the state and regional level. A new report will be released every other month. Subscribe to our list serve to be notified of reports when they are released.
This report outlines recent developments in the implementation of
FERC Order 2222 and DER policy. Key actions include FERC’s denial of rehearing on MISO’s
compliance filing, NYISO’s amendment to allow heterogeneous DER aggregations, and PJM’s
revised implementation timeline. State-level initiatives include Indiana’s stakeholder
process, Maryland’s DRIVE Act proposals, and coordination rulemaking in Virginia and Wisconsin.
The report emphasizes the growing importance of coordination among RTOs/ISOs, EDCs,
DER aggregators, and regulators, detailing compliance requirements and review processes.
It also highlights the evolving role of state and local regulators in setting communication
protocols and adjudicating override disputes.Read Report
Consumer Protections & CIM
July, 2025
The July 2025 Tracker Report outlines recent progress on FERC Order 2222,
highlighting regulatory actions across states and RTOs to integrate distributed energy resources
(DERs) into wholesale markets. The Key Issues Analysis emphasizes the need for consumer
protections, state-level policy development, and the creation of a centralized DER Registry.
The report also provides an introduction to the Common Information Model (CIM) and advocates
for broader adoption of CIM to standardize utility data and support the evolving grid, including
virtual power plants and local energy markets.Read Report
Double Counting & Double Compensation
May, 2025
This report highlights the topic of double counting and double compensation,
with each RTO/ISO adopting different compliance strategies. It emphasizes the importance of state and
local regulators in aligning retail and wholesale participation rules and recommends the creation of
a centralized DER Registry to support transparency, consumer choice, and market integrity. Current
news and developments include FERC’s approval of PJM’s third compliance filing, which delays
implementation to February 2028, and continued coordination efforts by MISO through its DER Task Force.
At the state level, Maryland’s PSC issued directives for DER registry development and IT system upgrades
to support VPPs, while Iowa opened a proceeding to evaluate the role of Aggregators of Retail Customers.
Virginia enacted the Community Energy Act and mandated a VPP pilot, and New York filed its first
“Grid of the Future” plan.Read Report
Aggregation Registration & Review
March, 2025
This report covers recent developments in the implementation of FERC Order 2222 and DER
policies. Key actions include compliance filings by MISO, state-level initiatives in Maryland and New
Jersey, and policy changes in Ohio and New York. The North American Energy Standards Board (NAESB) has
developed standard contracts and grid service definitions to support DER integration. The report also
outlines the registration and review processes for DER aggregations and aggregators, emphasizing the
roles of EDCs and state regulators in ensuring safety, reliability, and transparency.Read Report
Governance
January, 2025
This report summarizes the latest developments in FERC Order 2222 and DER Policy
implementation, including updates on MISO’s DER Task Force (DERTF), by the Indiana Utility Regulatory
Commission (IURC), the Staff of New Jersey Board of Public Utilities (NJBPU), the City of New Orleans,
the Commonwealth of Massachusetts, the Commonwealth of Virginia, and the U.S. Department of Energy
Commercial Liftoff report. The Key Issues Analysis of this report covers the topic of Governance,
with the following subtopics: FERC’s Jurisdiction over DER Aggregations, Jurisdiction, Registration
and Licensing of DER Aggregators and Dispute Resolution.Read Report
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