Reports

Communications Between DERAs & EDCs

January, 2026

The January 2026 report summarizes recent federal, regional, and state actions advancing FERC Order 2222 and DER policy. PJM, NYISO, and SPP progressed compliance filings, while several states—including Ohio, Pennsylvania, Colorado, Illinois, and Oregon—advanced interconnection reforms, virtual power plant programs, and microgrid frameworks. The report's key issue analysis focuses on communications between distributed energy resource aggregators (DERAs) and electric distribution companies (EDCs), identifying gaps in current RTO/ISO tariffs and the absence of clear state-level rules. It emphasizes the need for states to define communication requirements, data exchange standards, timeliness expectations, and cost recovery to ensure reliable DER participation in wholesale markets.Read Report

Metering and Telemetry

November, 2025

The November 2025 report reviews recent progress on FERC Order 2222 and DER policy; PJM and SPP advanced compliance filings, with PJM updating tariff provisions and SPP directed to refine rules for double counting and coordination ahead of a 2030 implementation. States like Indiana and Maryland moved forward on DER aggregation frameworks and virtual power plant deployment, while Iowa proposed enabling demand response in wholesale markets. A key focus is metering and telemetry—critical for DER participation—where RTOs/ISOs differ on requirements but increasingly allow submetering. The report stresses state action on standards, data access, and collaborative models to reduce costs and accelerate DER integration.Read Report

Coordination

September, 2025

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