Virtual power plants in the US
The standing record of US virtual power plants and what happens to them next.
Where things stand
As of September 5, 2026, US virtual power plants are growing through state programs and private capacity deals while wholesale market access under FERC Order 2222 arrives operator by operator; DOE's January 10, 2025 Liftoff update counted 33 GW across North America.
Order No. 2222, issued in 2020, requires every regional grid operator to open its markets to aggregations of distributed energy resources, on operator-set dates. DOE says CAISO and ISO New England have fully complied, "though implementation remains slow nationally." ISO New England's readiness page gives an effective date of November 1, 2026; NYISO's 2026 market project candidates calls for Order 2222 compliant software by the end of 2026; PJM's March 9, 2026 deck sets full go-live for February 1, 2028; MISO's September 10, 2025 timeline has aggregations in its day-ahead and real-time markets from January 1, 2030; and SPP's status report says FERC accepted its compliance filing on May 21, 2026, which proposed a second-quarter 2030 effective date.
Texas, outside FERC's jurisdiction, runs ERCOT's Aggregate Distributed Energy Resource pilot under PUCT Project No. 53911; on March 2, 2026 ERCOT raised its registered capacity limit from 200 MW to 500 MW.
California's Demand Side Grid Support program, which the California Energy Commission says offers incentives for load reduction and backup generation during extreme events from May to October, had an estimated 1,145 MW enrolled per the CEC's April 27, 2026 guidelines. Funding past 2026 is unsettled: SB 168 opened 2021 backup-assets money to DSGS through June 30, 2027 without stating an amount; AB 113, passed September 1, 2026, carries no new DSGS appropriation; and Advanced Energy United says the program "is currently funded only through the end of 2026" (California budget bill carries no 2027 money for its DSGS home-battery VPP). SB 913, requiring resource adequacy pathways for aggregated resources by June 30, 2028, awaits the Governor's action.
Under Governor Mikie Sherrill's Executive Order No. 2 of January 20, 2026, New Jersey board staff's July 15, 2026 straw proposal would launch a utility-run interim program no later than July 1, 2027 and an open-access tariff from 2029, and the board's August 17 storage straw would pay up to 150 MW of home batteries up to $200 per kilowatt-year for 10 years (New Jersey proposes 10-year payments for up to 150 MW of home batteries).
Colorado's program is in effect. The Public Utilities Commission approved Public Service Company of Colorado's aggregator program settlement in Decision No. C25-0903 on December 15, 2025; the utility's Advice Letter No. 2014 tariff, filed February 25, 2026 requesting an April 1, 2026 effective date, is listed as Effective on the PUC's docket sheet, and its program plan targets 25 MW a year, an estimated 125 MW by the end of 2030.
Sunrun, Renew Home, and Tesla announced on June 24, 2026 an agreement to deliver "more than 16 gigawatts" of flexible capacity to hyperscalers and utilities; Voltus's Google agreement aggregates up to 100 MW a year in PJM; and PG&E's SHARE pilot, announced September 3, 2026 and, per PG&E, fully funded by Google, aims to enroll nearly 21,000 home devices and gives no capacity figure (PG&E launches Google-funded SHARE virtual power plant in the Bay Area).
Timeline
- 2026
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PG&E announced SHARE, a Google-funded virtual power plant proof of concept that aims to enroll nearly 21,000 existing home devices in Alameda and Santa Clara counties (release).
Coverage PG&E launches Google-funded SHARE virtual power plant in the Bay Area
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SB 913, requiring resource adequacy pathways for aggregated distributed energy resources by June 30, 2028, was enrolled and presented to Governor Newsom (bill history).
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California's Senate passed and Assembly concurred in AB 113, the budget bill, with no appropriation for the Demand Side Grid Support program, though it reappropriates Item 3360-108-0001 of the Budget Act of 2021, the backup-assets money SB 168 opened to DSGS, for encumbrance or expenditure until June 30, 2027 (bill text).
Coverage California budget bill carries no 2027 money for its DSGS home-battery VPP
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PSE&G announced the GridSmart Battery Program, a $5,000 incentive toward a home battery that can be called on during utility peak events, ahead of both state programs (release).
Coverage PSE&G pays $5,000 toward home batteries in new VPP pilot
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Shell confirmed the completed sale of the German home battery and VPP company sonnen to the family office Tiven (Energy-Storage.News).
Coverage Shell completes sale of home battery maker sonnen to family office Tiven
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The New Jersey Board of Public Utilities announced its August 17 straw proposal for up to 150 MW of behind-the-meter residential storage paid up to $200 per kilowatt-year for 10 years, targeted to open by July 2027 and excluding any project under contract with a data center or other new large load (straw proposal).
Coverage New Jersey proposes 10-year payments for up to 150 MW of home batteries
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GridLab, Kevala, and E3 announced their California flexible-load blueprint, arguing that flexible load should be paid only for measured performance and below verified avoided cost, and that V2G should be accredited like grid storage (report).
Coverage GridLab: V2G could supply 30% of California's utility-scale storage target
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Sunrun agreed to supply capacity from a portion of its PJM and MISO residential fleet to Voltus's Bring Your Own Capacity programs for hyperscalers, without disclosing a megawatt figure (release).
Coverage Sunrun will supply home battery capacity to Voltus's AI hyperscaler deals
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The New Jersey board announced a July 30, 2026 public meeting in West Windsor Township to take stakeholder feedback on the VPP straw proposal (release).
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New Jersey board staff issued a straw proposal for a statewide VPP program, adopting a working definition of a VPP as an aggregation of DERs and other load management technologies that can balance electrical loads to defer or avoid transmission or distribution upgrades and provide "utility-scale, utility-grade grid services analogous to those provided by traditional generation resources," with an interim utility-run program launching no later than July 1, 2027, an open-access tariff from 2029, and an appendix sizing a 2 to 7 percent statewide peak shave at 393 to 1,374 MW (straw proposal).
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California's SB 168 was approved by the Governor as Chapter 81, making 2021 Distributed Electricity Backup Assets money also available to the Demand Side Grid Support program through June 30, 2027 (bill text; bill history).
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Sunrun, Renew Home, and Tesla announced a framework to deliver more than 16 GW of flexible capacity to hyperscalers and utilities from home batteries and more than 8 million smart thermostats and devices, with more than 300 MW they say is available in Virginia, expected to grow to at least 500 MW by 2030 (release).
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Voltus announced a three-year Bring Your Own Capacity agreement with Google for up to 100 MW a year of distributed resources in PJM (release).
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FERC accepted SPP's Order 2222 compliance filing, as amended on April 9, 2026, according to SPP's May 2026 regulatory status report (report).
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Ann Arbor's Sustainable Energy Utility began installing city-owned solar and batteries in the Bryant neighborhood (announcement).
Coverage Ann Arbor's city utility installs solar and batteries at no upfront cost
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The California Energy Commission approved the fifth edition of its DSGS guidelines, reporting an estimated 1,145 MW enrolled, $109.5 million allocated of an originally envisioned $314 million, and a $19.5 million cap on 2026 storage-VPP payments absent new funding (guidelines).
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Requested effective date of Public Service Company of Colorado's AVPP tariff, filed on more than thirty days' notice; the PUC's e-filings docket sheet for Proceeding No. 26AL-0078E lists the proceeding's status as Effective with no filings after February 25, 2026 (docket sheet).
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PJM's Order 2222 team laid out for stakeholders a schedule in which DERs are able to offer into the 2028/2029 Base Residual Auction under its aggregator model in the June 30 to July 7, 2026 window, enrollment begins in November 2027, and the full model goes live February 1, 2028 (presentation).
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ERCOT raised the ADER pilot's registered capacity limit from 200 MW to 500 MW while leaving its ancillary service limit at 100 MW (market notice).
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Public Service Company of Colorado filed Advice Letter No. 2014 and its AVPP program plan to implement the approved Colorado program: 25 MW per year, a generation capacity incentive of $151.70 per kW-year for year-round aggregations or $106.19 for summer-only ones plus smaller transmission and distribution incentives, rates fixed for five years for first-year aggregations, up to 80 load control events a year for year-round aggregations and 60 for summer-only ones of at most four consecutive hours, and an estimated 125 MW enrolled by the end of 2030 (advice letter; program plan).
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Governor Sherrill signed Executive Order No. 2, declaring a State of Emergency and directing the board to commence development of a VPP program within 180 days (order).
- 2025
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The Colorado Public Utilities Commission issued Decision No. C25-0903, granting the settlement on Public Service Company of Colorado's Aggregator Virtual Power Plant program "without modification," calling it "a reasonable approach for launching Colorado's first VPP Program" but "not the VPP program we expect to have in the coming years" (decision).
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The CEC's December 2025 status report put DSGS at more than 448,000 participants and an estimated load reduction capacity of more than 1 GW as of November 30, 2025, based on provider estimates (report page).
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SPP made its third Order 2222 compliance filing, proposing an effective date in the second quarter of 2030 and asking FERC for an order by February 13, 2026 (filing).
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MISO gave its Distributed Energy Resources Task Force a revised Order 2222 timeline: aggregated resource enrollment available June 1, 2029, day-ahead and real-time market participation January 1, 2030, and capacity market participation from June 1, 2030 (minutes).
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The Brattle Group, commissioned by Sunrun and Tesla Energy, estimated $28 million to $206 million in net system savings from DSGS over 2025 to 2028 and reported an average net-load reduction of 539 MW during a July 2025 test event (release).
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Public Service Company of Colorado filed the settlement agreement on its Aggregator Virtual Power Plant program (Hearing Exhibit 131) that the commission later approved (decision).
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NYISO's 2026 market project candidates list scheduled deployment of Order 2222 compliant software by the end of 2026, building on the FERC-accepted DER participation model it deployed in 2023 (project descriptions).
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FERC approved all outstanding items of PJM's Order 2222 aggregator model, with full go-live set for February 1, 2028, per PJM (PJM presentation, March 9, 2026).
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Public Service Company of Colorado filed its Aggregator Virtual Power Plant application, Proceeding No. 25A-0061E, proposing about $78.5 million for 25 MW of capacity a year over five years (PUC proceeding page).
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DOE released its Liftoff update on virtual power plants, counting 33 GW across North America, describing 80 to 160 GW by 2030 as enough to serve 10 to 20 percent of peak load that could support rapid load growth while reducing overall grid costs, and saying CAISO and ISO New England had fully complied with Order 2222 "though implementation remains slow nationally" (announcement).
- 2024
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CAISO's business requirements specification for Order 2222, which references its August 15, 2022 tariff filing, scheduled the implementation release for November 1, 2024, reducing the minimum aggregation size to 100 kW and adding heterogeneous aggregations (specification).
- 2022
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California's AB 205, authorizing the Demand Side Grid Support program, which the CEC's program page describes as incentives for load reduction and backup generation during extreme events from May to October, was approved by the Governor and chaptered as Chapter 61, Statutes of 2022 (bill history; CEC program page).
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ISO New England made its primary Order 2222 compliance filing (key project page).
- 2020
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FERC issued Order No. 2222, requiring RTOs and ISOs to open their capacity, energy, and ancillary service markets to aggregations of distributed energy resources; the rule was published October 21, 2020, took effect December 21, 2020, and set compliance filings due September 17, 2021 (Federal Register).
Next milestone
September 10, 2026: written comments are due in New Jersey Board of Public Utilities Docket No. QO26040116 on the Garden State Energy Storage Program Phase 2 Block 1 straw proposal. They will appear in the board's Public Document Search under that docket number. Watch whether aggregators and developers argue the $200 per kilowatt-year rate up toward the $300 the proposal's own gap analysis indicated, and what they say about the 35-event annual dispatch cap and the four utilities' megawatt allocations; the straw expects a board order in October 2026. After that, September 30, 2026 is the Governor's deadline to act on SB 913 under Article IV, Section 10(b)(2) of the California Constitution; November 1, 2026 is ISO New England's effective date for Order 2222 participation; and the New Jersey VPP straw states that aggregators wanting to participate in PJM's 2030/2031 Base Residual Auction must submit a notice of intent to PJM by December 1, 2026.
This is a maintained page: it is revised as the record changes, and every revision is reviewed before it goes live. Dates in the text are the dates the facts hold for, not the date you are reading it.
Sources
Primary
- Business Requirements Specification: FERC Order 2222 (Document Version 1.2) · California Independent System Operator
- 2026 Market Project Candidates (Product and Project Management), Section 29: FERC Order 2222 Compliance · New York Independent System Operator
- Distributed Energy Resources Task Force (DERTF) September 10, 2025 Minutes · MISO
- Order No. 2222 Compliance Filing in Response to September 2025 Order, Docket No. ER22-1697-004 · Southwest Power Pool, Inc.
- Proceeding Detail, 26AL-0078E: Public Service Company - AL 2014 - Tariff 8 - AVPP · Colorado Public Utilities Commission (E-Filings)
- Regulatory Status Report (May 2026), ER22-1697 Order No. 2222 Compliance Filing · Southwest Power Pool, Inc.
Supporting
- Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators (Order No. 2222), 85 FR 67094 · Federal Energy Regulatory Commission via Federal Register
- AB-205 Energy (2021-2022) bill history · California Legislative Information
- U.S. Department of Energy Releases New Reports Highlighting Benefits of Consumer-Centric Solutions for Households, Businesses, and Utilities (Pathways to Commercial Liftoff: Virtual Power Plants Update) · U.S. Department of Energy, Office of Technology Transitions
- Distribution System Plans (Public Service 2025-2029 Distribution System Plan; Aggregator Virtual Power Plant Program, Proceeding No. 25A-0061E) · Colorado Public Utilities Commission
- Brattle Report Finds California's Distributed Power Plant Program Could Deliver Hundreds of Millions in Cost Savings While Supporting Grid Reliability · The Brattle Group via PR Newswire
- Demand Side Grid Support and Distributed Electricity Backup Assets Status Report - December 2025: AB 205, AB 1373 · California Energy Commission
- Decision No. C25-0903: Commission Decision Granting Applications with Modifications, Requiring Filings, Addressing Motions, and Issuing Certain Directives to Guide Future Filings (Proceeding Nos. 24A-0547E & 25A-0061E) · Colorado Public Utilities Commission
- Order No. 2222 Key Project · ISO New England
- Executive Order No. 2 (Governor Mikie Sherrill) · State of New Jersey, Office of the Governor
- Attachment 1, SB24-218 Aggregator Virtual Power Plant (AVPP) Program Plan · Public Service Company of Colorado (Xcel Energy)
- Advice Letter No. 2014 - Electric (Aggregator Virtual Power Plant program tariff, Colorado P.U.C. No. 8 Sheets 124-124I) · Public Service Company of Colorado (Xcel Energy)
- M-A030226-01 Updates to ADER Pilot Participation Limits · ERCOT
- DER Aggregator Participation Model: Full Model Design (Informational Only), DISRS March 9, 2026 · PJM Interconnection
- Demand Side Grid Support Program · California Energy Commission
- Demand Side Grid Support (DSGS) Program Guidelines, Fifth Edition (CEC-300-2026-001-CMF) · California Energy Commission
- Ann Arbor Sustainable Energy Utility marks milestone with first installations in Bryant neighborhood · City of Ann Arbor
- Voltus and Google to Deliver Grid Capacity and Local Economic Benefits Through Bring Your Own Capacity Agreement · Voltus, Inc.
- Aggregate Distributed Energy Resource (ADER) Pilot Project · ERCOT
- Sunrun, Renew Home, and Tesla Team Up to Deliver More Than 16 Gigawatts of Fast, Flexible Power for Data Centers and Large Loads · Renew Home (joint release with Sunrun and Tesla)
- SB-168 Public Resources (Chapter 81, Statutes of 2026) · California Legislative Information
- SB-168 bill history · California Legislative Information
- Straw Proposal: Virtual Power Plant Program (Docket No. QO26030099) · New Jersey Board of Public Utilities (Staff)
- NJ Proposes "Virtual Power Plant" Plan to Save Ratepayers Millions Annually · New Jersey Board of Public Utilities
- Garden State Energy Storage Program (GSESP) Phase 2: Distributed Energy Storage Capacity Block 1 Straw Proposal · New Jersey Board of Public Utilities
- Sunrun to Supply Voltus with Energy Capacity for AI Hyperscaler Agreements · Sunrun Inc.
- Unlocking California's Flexible Load: A Durable Blueprint for Affordability and Reliability · GridLab, Kevala, and E3
- NJBPU Advances Statewide Home Batteries Program with New Garden State Energy Storage Proposal · New Jersey Board of Public Utilities
- SB-913 Resource adequacy: aggregated distributed energy resources · California Legislative Information
- Shell offloads residential battery storage and VPP provider sonnen after seven years · Energy-Storage.News
- FERC Order No. 2222 (Participant Readiness Outlook) · ISO New England
- PSE&G Introduces GridSmart Battery Program, a New Residential Battery Storage Pilot · PSE&G
- AB-113 Budget Act of 2026 (amendments), as amended August 28, 2026 · California Legislative Information
- California Turns Its Back on Proven Low-Cost Reliability Program · Advanced Energy United
- SB-913 bill history · California Legislative Information
- PG&E, Rewiring America and Google Launch First-of-its-Kind Virtual Power Plant to Help Lower Costs for All Customers · Pacific Gas and Electric Company
- California Constitution, Article IV, Section 10 · California Legislative Information