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 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 report’s 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
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
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