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Parties filed responses to the VPP RFI -Virtual Power Plant (VPP) Request for Information (RFI)  -issued on April 20, 2026 and revised on May 6, 2026  concerning the evaluation and development of distributed energy resource (“DER,” collectively, “DERs”) programs across two coordinated program areas: the Virtual Power Plant (“VPP”) Program and Phase 2 (Distributed Storage Segment) of the Garden State Energy Storage Program (“GSESP”)..

Comments include:

JCPL– Jersey Central Power & Light Company (JCP&L) states that “JCP&L recognizes and supports the State’s timely efforts to explore demand‑side and distributed solutions to address largely wholesale‑driven generation price pressures. At the same time, potential VPP frameworks should not be considered in isolation, but rather as part of a broader portfolio of State initiatives that collectively influence customer‑sited technology adoption and grid outcomes.”

“JCP&L encourages the Board to consider whether VPP‑enabling technologies would be more effectively supported under a coordinated or consolidated framework that explicitly recognizes their cross‑program value, rather than implemented piecemeal through multiple and potentially competing initiatives. Such coordination would better ensure that customer investments, utility systems, and third‑party platforms evolve in a complementary manner aligned with State objectives.”

“JCP&L recommends a staged approach to VPP development that allows initial programs or pilots to be designed in alignment with each EDC’s current capabilities and planning needs. Pilot programs provide an important opportunity to validate performance assumptions, assess customer participation, evaluate aggregator coordination models, and understand real‑world cost impacts relative to delivered benefits. Results from early pilots can then inform subsequent program phases and enable successful approaches to be refined and scaled over time. This approach supports the Board’s objective of progress while appropriately managing implementation risk.”

“State‑directed VPP programs should be designed to complement, rather than replicate or compete with, existing and emerging PJM market structures. VPP use cases that provide localized reliability services, distribution system optimization, or other non‑wholesale products are more appropriately addressed through state‑level programs. Conversely, program elements that mirror wholesale market products or requirements risk inefficiencies and unnecessary cost.

Similarly, state programs should avoid transferring responsibilities that appropriately rest with DER aggregators (“DERA,” collectively, “DERAs”) to utilities and ratepayers. Obligations related to DER registration, aggregation thresholds, wholesale metering, telemetry, and data provision necessary for participation in PJM markets are appropriately addressed within RTO frameworks. Requiring utilities to modify AMI infrastructure, data systems, or operational processes to support wholesale market compliance by third‑party aggregators would impose costs on customers without corresponding utility planning benefits.”

Retail Energy Supply Association strongly urged BPU “to accelerate its adoption of a final AMI Data Access rulemaking and to initiate an accelerated proceeding regarding the AMI meters installed by PSE&G, JCP&L, and ACE that cannot provide interval usage data at a sufficiently granular level,” noting that: (i) it “has repeatedly urged the Board to finalize the AMI Data Access rules so that TPSs can have access to customers’ AMI data” since 2020; and (ii) the RFI asks about AMI capabilities when “PSE&G and JCP&L already informed the Board over 18 months ago… that their installed AMI meters are not capable of providing 15-minute interval data for residential customers, let alone the 5-minute interval data required for DER aggregation and VPPs, and that new AMI meters would need to be installed in order to provide that level of usage data granularity”;

New Jersey Utilities Association: (i) recommended “that the development of a VPP program should proceed in a measured, phased manner that is limited in scope, voluntary, and learning-oriented”; (ii) suggested that “Targeted pilot programs could also be incorporated into upcoming plans” and “The next phase could be initiating a front-of-the-meter battery storage program through the GSESP to utilize existing system technologies and deploy large amounts of battery storage where it is most beneficial to the distribution grid and customers,” noting that “Behind-the-meter (‘BTM’) programs that involve export will require significant technology upgrades and time to implement”; (iii) recommended BPU “consider a more integrated and sequenced planning approach that aligns VPP development, energy storage deployment, DER integration, demand response/load curtailment, and grid modernization initiatives to avoid duplicative or conflicting requirements”; (iv) requested that BPU “establish opportunities for ongoing, structured engagement with utilities and other stakeholders to facilitate alignment, improve program design, and help identify potential implementation challenges at an early stage”; (v) said that “clarity is needed regarding the nature of the services to be provided through a VPP construct,” emphasizing that “program design should clearly distinguish distribution-level services from wholesale market participation and should avoid inadvertently implicating generation or capacity products unless expressly intended”; (vi) requested “greater clarity on governance and decision rights, including who sets dispatch priorities, how conflicts between distribution needs and aggregation objectives are resolved, and how program changes will be approved over time”; and (vii) said that utility “ownership of storage may maximize grid and customer benefits, and the Board should consider allowing utilities to propose such configurations where appropriate.”

Lunar Energy filed detailed comments addressing specific questions included in RFI.

See: NJBPU_VPP_RFI_RESPONSE_LUNAR_ENERGY

Read all filed comments at docket link here. 

As background the New Jersey BPU initiated this proceeding to oversee development of grid flexibility services (GFS) for aggregated distributed energy resources (DER). This includes the GFS working group, the second of the Grid Modernization Forum’s working groups, whose findings will be used to develop tariff language for grid flexibility services and subsequent virtual power plant (VPP) programs.

The GFS working group’s primary goal is “to create a service architecture that standardizes the integration, interoperability, aggregation and orchestration of interconnected and aggregated DER, such that a broad range of flexibility services can be called upon from these assets.” It will focus on:

• characterizing needed grid service elements;
• identifying interoperability barriers for heterogeneous DER service delivery;
• determining appropriate service value and compensation; and
• initiating data collection pilots for developing a commercial scale VPP program.