Demand Response (Rider T) Program Guidelines – 2025 Capability Period.
Component
Technical
Author
Con Edison
Stakeholder
Third-party grid edge resource aggregators (also called Curtailment Service Providers) enrolling customers in Con Edison’s distribution-level demand response programs; end-use customers those aggregators recruit; and Con Edison as the overseeing utility.
Provides enrollment, meter data and communications, event, and settlement guidance for entities enrolling in Con Edison's demand response programs.
State regulatory opportunities to advance grid edge resource aggregations in wholesale markets
Component
Technical
Author
Sydney Forrester; Ryan Hledik; Adam Bigelow; Natalie Mims Frick; Kala Viswanathan (Lawrence Berkeley National Laboratory – Energy Markets & Policy Department)
Stakeholder
State public utility commissions (regulators), distribution utilities, grid edge resource Aggregators, and RTO/ISO market operators – focusing on the interaction among these in compliance oversight.
Identifies how state regulators and utilities can enforce compliance for grid edge resource aggregators participating in RTO/Independent System Operator markets (under FERC Order 2222). It reviews the FERC Order 2222 compliance filngs of market operators and highlights remaining challenges in monitoring and enforcement, then outlines actions states can take to bolster reliability. For example, the report suggests that states establish provisions to penalize underperformance by grid edge resource aggregators when a distribution utility’s override of an aggregator’s dispatch leads to lost expected output. In other words, if a utility must curtail an aggregator’s resources for safety, the aggregator could face a performance penalty for failing to deliver contracted services when a distribution utility’s override of an aggregator’s dispatch leads to lost expected output. This creates an incentive for aggregators to coordinate closely with utilities to avoid overrides. The report also discusses frameworks for utility-aggregator coordination (such as communication protocols to give utilities override capability) and oversight measures to ensure aggregators comply with both market rules and distribution reliability needs. It emphasizes real-world enforcement—e.g., requiring aggregators to meet registration requirements, adhere to dispatch limits set in utility review processes, and face penalties or removal from programs if they don’t comply.
Uniform Business Practices for grid edge resource Suppliers (UBP-DERS), Case 15-M-0180
Component
Institutional
Author
New York State Public Service Commission (PSC)
Stakeholder
New York State Public Service Commission PSC, New York State Department of Public Service DPS, New York Independent System Operator NYISO, Long Island Power Authority, Energy Service Companies.
This document establishes Uniform Business Practices for grid edge resource suppliers in New York. It sets rules for sales agreements, marketing standards, data security, complaint handling, and regulatory oversight. It aims to protect customers from deceptive practices, ensure clear contract terms, and define the rights and responsibilities of grid edge resource providers.
Order on DRIVE Act On-Site Generating System Incentives and DER Aggregator Licensing
Component
Institutional
Author
Maryland Public Service Commission
Stakeholder
Maryland Investor-Owned Utilities (Baltimore Gas And Electric Company, Pepco, Delmarva, Potomac Edison); third-party DER aggregators like CPower (which commented in the proceeding) ; potentially Pennsylvania-New Jersey-Maryland market participation via ag
Implements Maryland’s DRIVE Act by establishing a licensing framework for DER aggregators. It confirms PSC authority over DER aggregators, seekings to protect consumers while avoiding onerous requirements . The order sets direction for regulations and oversight of DER aggregators interacting with wholesale markets.
Distribution Standard of
Conduct - A Reference Guide for Electric Retail Regulators
Component
Business
Author
DOE
Stakeholder
distribution utilities (investor-owned, municipal, cooperative) that interconnect or aggregate grid edge resources, and state regulators overseeing them. Also impacts grid edge resource aggregators and third-party service providers who require impartial a
Establishes a code of conduct for distribution utilities to ensure non-discriminatory, open access distribution service as grid edge resource aggregations grow under FERC Order 2222. It adapts Federal Energy Regulatory Commission's (FERC’s) transmission open-access principles (non-discrimination, independent functioning, no conduit, transparency) to the distribution level . The document provides example guidelines to prevent conflicts of interest when utilities both operate the grid and compete in grid edge resource markets, ensuring ongoing compliance with fair access rules.
Third-Party Aggregation Rulemaking in MISO and SPP Footprints.
Component
Technical
Author
Sydney Forrester, Cole Triedman, Sam Kozel, Cameron Brooks, and Peter Cappers – Lawrence Berkeley National Laboratory (Energy Markets & Policy Group).
Stakeholder
State public utility commissions and regulated utilities in MISO/SPP states (mostly vertically-integrated utilities in Midwest/South regions) are the primary audience. Third-party grid edge resource aggregators (e.g., CPower, Voltus) and retail customers
Provides a technical framework for state regulators on integrating third-party grid edge resource aggregators into the distribution grid and coordinating with wholesale markets . It highlights key considerations (jurisdiction, registration/licensing, data governance, dual participation rules, dispute resolution mechanisms, etc.) for states that previously banned retail aggregators and are now revisiting those rules in light of FERC Order 2222 and evolving grid needs . The report includes implementation details such as tiered options for state action and examples of how various states handle aggregator oversight (e.g., setting up customer data access protections and processes to resolve utility-aggregator conflicts).
PURA Final Decision in Docket No. 17-12-03RE07, Non-Wires Alternatives
Component
Technical
Author
Connecticut Public Utilities Regulatory Authority
Stakeholder
Electric Distribution Companies in Connecticut (United Illuminating and Eversource Connecticut) must adapt their planning and investment processes; third-party grid edge resource developers gain new market opportunities; regulators (PURA) and stakeholders
Establishes a transparent, competitive procurement and evaluation process for Non-Wires Alternatives in Connecticut. In this 2022 decision, the Public Utilities Regulatory Authority (PURA) set out how the electric utilities must identify distribution system needs (e.g., overloaded substations or reliability issues) and solicit grid edge resource proposals as alternatives to building new infrastructure . It provides a cost-benefit framework to compare grid edge resource solutions versus traditional wires solutions to ensure that ratepayer benefits are maximized . The decision covers cost allocation and recovery by allowing utilities to recover NWA project payments and rewarding them for cost-effective grid edge resource deployments (while protecting customers by only approving projects that are cheaper or more beneficial than the wires option). It is an operational roadmap for utilities to integrate grid edge resources in distribution planning, including standardized benefit-cost analysis, competitive bidding, and contractual mechanisms to fairly pay grid edge resource providers.
Grid Edge Resource Strategy (section in NERC’s November 2022 Reliability Risk Committee agenda)
Component
Technical
Author
NERC
Stakeholder
NERC System Planning Impacts from Distributed Energy Resources Working Group (tasked with Grid Edge Resource Integration issues – cited in the paper) ; FERC (for any future jurisdictional changes); large grid edge resource aggregators (e.g., those managin
The North American Electric Reliability Corp.’s strategy document addresses the reliability challenges of rapid Grid Edge Resource growth and the emergence of the grid edge resource aggregator role. It notes that grid edge resource aggregators, as introduced by FERC Order 2222, present “unique operational benefits and challenges” for grid planners and operators . NERC discusses potential new oversight: e.g., whether large grid edge resource aggregators should be registered entities for reliability standards compliance, and how to coordinate transmission-distribution operations as aggregations grow . It also flags cybersecurity concerns with aggregators controlling many distributed assets . This strategy guides how reliability rules might evolve to include grid edge resource aggregators.
Lawrence Berkeley National Laboratory technical report; Natalie Mims Frick, Snuller Price, Lisa C. Schwartz, Nichole L. Hanus, and Ben Shapiro
Stakeholder
Utilities and state utility regulators/planners . It also informs third-party grid edge resource providers and customers by clarifying how grid edge resource aggregations can be valued in utility planning.
Provides a detailed analysis of the potential benefits (“locational value”) of aggregated grid edge resources on distribution systems and methodologies to quantify those benefits. The report describes approaches and tools for calculating grid edge resource value in specific locations and includes 24 case studies illustrating how different U.S. utilities and states evaluate grid edge resources as alternatives to infrastructure investments . This technical report is intended to inform utility planning and regulatory decisions by showing where and how grid edge resource aggregations can defer or avoid conventional grid investments.
An Act to Reduce Electricity Costs through Nonwires Alternatives
Component
Business
Author
State of Maine
Stakeholder
State of Maine
Describes a law passed in Maine to implement non-wires alternatives (NWA) projects. The law directs the Maine Office of the Public Advocate to contract with a NWA coordinator to review utility proposals for significant transmission and distribution investments.
Enabling Third-Party Aggregation of Grid Edge Resources
Component
Technical
Author
Janine Migden-Ostrander, John Shenot, Camille Kadoch, Max Dupuy, Carl Linvill – The Regulatory Assistance Project (prepared for Arkansas PSC under a DOE grant)
Stakeholder
Third-party grid edge resource aggregators (termed ARCs) seeking to do business in Arkansas; electric utilities (like Entergy Arkansas) that will interact with these aggregators; and retail customers who may enroll with aggregators. The report was crafted
This is a technical guidance report for the Arkansas Public Service Commission detailing how to establish a regulatory framework to oversee third-party grid edge resource aggregators at the grid edge . It covers implementation details such as aggregator certification requirements, performance metrics, and especially consumer protection measures. For example, it proposes a “code of conduct” for utilities engaging with affiliate aggregators and a commission oversight regime that includes compliance plans, audits, and explicit complaint procedures and logs for customer issues . The report spells out how the PSC can handle customer data sharing, require transparent marketing and truthful performance claims, and adjudicate customer complaints about aggregators’ services . An appendix provides draft model rules for aggregator registration, ensuring only financially and technically capable entities with consumer safeguards can operate.