VPP policy and regulation: the rules that decide who gets paid

Federal market rules, state programs, and utility tariffs set the size of the VPP paycheck. Here is where they stand and what is coming.

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The short answer

Federal rules opened the door. FERC Order 2222 requires regional grid operators to let aggregations of distributed resources as small as 100 kW into wholesale markets; aggregators are paid and may share revenue with customers (FERC).
But implementation is slow. Only CAISO is live (November 2024). ISO-NE and NYISO follow in late 2026, PJM in February 2028, MISO in 2029, and SPP in 2030 (PNNL).
States are moving faster with their own VPP programs and tariffs — New Jersey, Illinois, Maryland, Virginia, Texas, California, and New York are the ones to watch.
Policy is the biggest risk to VPP income. Several of the best-paying programs depend on annual budgets or are still proposals.

When each grid operator opens its markets to DER aggregations

FERC Order 2222 effective dates by regional grid operator.

Swipe to see the full chart →

Sources: PNNL; FERC. ERCOT (Texas) is outside FERC’s jurisdiction and runs its own ADER pilot.

State actions to watch

New Jersey

Distributed storage Block 1

Up to 150 MW of home and business storage at up to $200 per kW-year for 10 years; open-access VPP tariff planned for 2029 (Utility Dive).

Illinois

ComEd Rider SDVPP

$10 per kW-season for storage VPP participation starting 2027 (Energy Choice Matters).

Maryland

DRIVE Act pilots

VPP and vehicle-to-grid pilots approved for summer 2027 (Vehicle-Grid Integration Council).

Virginia

Dominion VPP pilot

Dominion Energy launched a VPP pilot in August 2026 (Dominion Energy).

Texas

ERCOT ADER pilot

Aggregated distributed resources in the wholesale market: up to 500 MW for energy and 100 MW for ancillary services; protocol package targeted for Q4 2026 (ERCOT). ERCOT is not subject to Order 2222.

California

DSGS and new VPP bills

DSGS pays batteries during grid emergencies but depends on annual funding; SB 913 and SB 905 awaited the governor’s signature in late September 2026 (pv magazine USA).

New York

Battery load management

Utility programs pay about $50 per kW-year for batteries, about $180 a year for a 3.6 kW enrollment (NYSERDA).

Method and caveats

This page summarizes policy for consumers and is not legal advice. Checked October 1, 2026; dates are as published and may slip.

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