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.
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
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
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