FERC Order 2222 & DER Policy Implementation Bi-Monthly Reports
These bi-monthly reports were a series designed to track and deep dive into DER policy implementation at the state and regional level. The July 2026 report is the final report in this series; no new reports will be published.
The July 2026 report highlights major milestones in FERC Order 2222
implementation, including approval of SPP’s compliance filing and continued state
action on virtual power plants, energy storage, advanced metering, and DER
aggregation in Vermont, New Jersey, Michigan, and the District of Columbia.
The Key Issues Analysis examines DER interconnection requirements under Order
2222, including the division of state and RTO/ISO responsibilities and emerging
efforts to modernize interconnection processes and support wholesale market participation.Read Report
Enabling DERs Through Industry Collaboration
May, 2026
The May 2026 report highlights recent progress in FERC Order
2222 implementation and DER policy development. SPP advanced its compliance
filing, while Massachusetts, New Jersey, Maryland, Minnesota, and New York
launched or expanded initiatives supporting virtual power plants, energy
storage, DER data access, demand response, and grid modernization. The Key
Issues Analysis focuses on two companion white papers that make the case for
a more integrated approach to DER planning and valuationRead Report
Communications and Controls for DERs
March, 2026
The March 2026 report summarizes recent actions
advancing FERC Order 2222 and DER integration; PJM
continued updating its DER aggregation tools and procedures, while states including
Pennsylvania, Virginia, Illinois, New Jersey, and Maryland advanced interconnection
reform, VPP pilots, DER aggregation mandates, and demand-side management coordination.
NAESB also continued work on voluntary DER entity and device registry standards.
The key issue analysis focuses on communications and controls for DERs,
emphasizing the need for shared data definitions and a common industry ontology. It
highlights the Common Information Model (CIM) as a proven framework for consistent,
scalable DER data exchange and argues that broader adoption across distribution utilities
is essential to reduce costs, improve interoperability, and maintain bulk power system
reliability as DER participation grows.Read Report
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
