Every DER value stream in the desert Southwest.
There is no RTO or ISO here, so Order 2222 has nothing to attach to. In 2024 two of fourteen cooperatives reported a demand-response program on Form 861.
August 2026 · Texture · Practitioner reference for cooperatives and municipal utilities

2 of 14
Cooperatives reporting demand response on EIA Form 861; CommonGrid finds four
9,072 MW
SRP record peak on July 24, 2026; APS hit 9,053 MW the same hour
690.7 MW
Actual peak demand savings from 353,436 enrolled customers in 2024
About this report
Arizona, Nevada, and the part of New Mexico outside SPP served 5.62 million residential and commercial distribution customers and 142.8 terawatt-hours of retail sales in 2024. Investor-owned utilities serve 71.8 percent of accounts, public power 23.2 percent, and cooperatives 5.0 percent. Twelve utilities reported a demand-response or load-management program in 2024, enrolling 353,436 customers and delivering 690.7 MW of actual peak demand savings. APS delivered a record 9,053 MW and SRP a record 9,072 MW on July 24, 2026.
Key findings
Why is there no Order 2222 pathway in the Southwest?
FERC Order 2222 applies to regional transmission organizations and independent system operators, and this region has neither, so the obligation to open a market to DER aggregations has nothing to attach to. A battery in Phoenix or Reno has no wholesale market to bid into. Every dollar of DER value in this footprint has to come from a utility program, a retail rate, a tax credit, or an avoided cost inside a utility's own planning.
How are Arizona and its neighbors splitting on markets and mandates?
Arizona Public Service, Salt River Project, Tucson Electric Power, and UniSource have committed to SPP's Markets+ in 2027 and to binding WRAP operations in winter 2027/28. Public Service Company of New Mexico and NV Energy chose CAISO's Extended Day-Ahead Market and filed WRAP exit notices in October 2025. Arizona repealed its Renewable Energy Standard and Tariff on March 4, 2026. Nevada still has a 50 percent RPS for 2030; New Mexico's Energy Transition Act requires investor-owned utilities to be 100 percent carbon-free by 2045, with cooperatives following by 2050.
Get the DER Value in the Southwest Report.
Frequently asked questions
How many Southwest cooperatives run a demand-response program?
On EIA Form 861, two of fourteen cooperatives reported a program in 2024. The CommonGrid registry, which counts programs a cooperative operates under its own name, finds four of the fourteen, all in Arizona and all members of Arizona Electric Power Cooperative. Seven of nine investor-owned utilities run a program.
Who sets cooperative rates in Arizona?
The Arizona Corporation Commission, which is unusual: cooperatives in most states set their own retail rates through their boards. Trico, Sulphur Springs Valley, Mohave, Duncan Valley, Graham County, and Navopache all file rates with the ACC. Salt River Project answers to its own elected board and no commission at all.
Which New Mexico cooperatives are still in this footprint?
Most of New Mexico's cooperative sector left this footprint on April 1, 2026, when Tri-State joined SPP West and carried eleven member cooperatives with it. What remains is PNM, El Paso Electric, the Navajo Tribal Utility Authority, and Kit Carson Electric Cooperative, which bought its way out of Tri-State in 2016, serves nearly 30,000 members, and has reached 100 percent daytime solar across its territory since the summer of 2022.