The Missouri Public Service Commission modified its prior policy to allow third-party aggregators of retail customers to enroll large commercial and industrial (C&I) loads in wholesale market demand response programs. In an October 2023 order, the PSC partially lifted its 2010 ban on retail demand response aggregation, permitting C&I customers with a load ≥100 kW to participate in Midcontinent Independent System Operator (MISO)/Southwest Power Pool wholesale demand response either directly or through an ARC . (Smaller customers and those already in utility DR programs remain under the ban for now.) The purpose is to gain experience with DER aggregators providing wholesale services while maintaining reliability for other ratepayers . This ruling established conditions for utility-aggregator coordination and ensured only eligible large customers (often with on-site generation or flexible load) can be aggregated, thereby managing any cost or grid impact. The order explicitly notes it is a “partial” opt-in, with the PSC retaining the retail opt-out for residential and small customers until further review.

In response to FERC Order 2222, the Indiana Utility Regulatory Commission initiated stakeholder meetings to discuss the integration of grid edge resource aggregations into wholesale markets. Key areas of discussion include interconnection processes, operational oversight, cost allocation, and the regulatory status of grid edge resource aggregators. The goal is to develop rules and procedures that facilitate grid edge resource participation while maintaining grid reliability.

This report, written to assist the Arkansas Public Service Commission, discusses the regulatory considerations for allowing third-party aggregators to participate in energy markets. It emphasizes the importance of establishing a code of conduct to ensure fair competition between utilities and aggregators, protect consumer interests, and create a robust market environment.

The New York PSC established a standardized aggregator code of conduct to ensure fair, transparent grid edge resource markets. It sets uniform rules for marketing, data sharing, and customer protections—prohibiting deceptive practices, defining rights and responsibilities, and requiring standardized disclosures and utility coordination to support oversight and ethical aggregator operations.

The California Public Utilities Commission issued a decision establishing 11 rules to govern how energy storage grid edge resources can "stack" multiple services across the distribution system and wholesale market. The goal was to enable storage to realize full economic value by providing services in different "domains" (customer, distribution, transmission, wholesale) while maintaining reliability. For example, a battery on the distribution grid may also provide resource adequacy and California Independent System Operator wholesale market services. The rules prioritize reliability over other uses and ensure no conflicting obligations or double payments for the same service. This ruling effectively set the framework for DER aggregators to offer distribution-level services and participate in wholesale markets under clear conditions.