Lawrence Berkeley National Laboratory's Report on Grid Edge Resource Participation in Wholesale Markets
Component
Institutional
Author
Lawrence Berkeley National Laboratory
Stakeholder
State Regulatory Commissions, DER aggregators, Regional Transmission Organizations
Explore state regulatory opportunities to advance grid edge resource participation in wholesale markets. The report addresses challenges such as dual compensation and emphasizes the need for clear procedures and documentation to validate grid edge resource participation strategies.
Pennsylvania Public Utility Commission's Advance Notice of Proposed Rulemaking (ANOPR) on Grid Edge Resource Participation
Component
Institutional
Author
PA PUC
Stakeholder
Duquesne Light Company, UGI Utilities, Inc., Electric Division, and other Pennsylvania electric distribution companies (EDCs)
Seek comments on adapting existing interconnection and metering regulations to address the integration and participation of grid edge resource aggregation resources in wholesale markets. It focuses on preventing dual compensation, ensuring accurate registration, and maintaining grid reliability.
Saumil Patel (ICF) and Paul De Martini (Newport Consulting)
Stakeholder
Distribution utilities, grid edge resource aggregators, state regulators (PUCs/Relevant Electric Retail Regulatory Authorities), and RTO/ISO market operators involved in Grid Edge Resource Aggregation coordination.
A DOE-sponsored report that establishes a standard Distribution Services Contract between an electric distribution utility and a grid edge resource aggregator. It defines consistent terms for grid edge resource services and outlines processes to validate aggregator registration information (e.g., grid edge resource locations, sizes, technologies, and planned markets) against distribution tariffs, interconnection requirements, and wholesale market rules. The contract framework covers validation and qualification of grid edge resource aggregations, ensuring each resource meets eligibility criteria (such as retail program limits and wholesale market minimums) before participation.
Indiana Michigan Power Company February 2, 2023 Comments on IURC Implementation of FERC Order 2222
Component
Business
Author
Indiana Michigan Power Company (utility regulatory team; formal comments submitted by the company).
Stakeholder
Indiana Michigan Power (I&M), PJM Interconnection, FERC, IURC, Grid Edge Resource Aggregators operating in PJM territory, retail electricity customers with grid edge resource assets in Indiana, technology providers supporting Grid Edge Resource Integratio
A set of comments submitted by Indiana Michigan Power (an American Electric Power [AEP] utility) to the Indiana Utility Regulatory Commission (IURC) regarding the implementation of Federal Energy Regulatory Commission (FERC) Order 2222. The document discusses how distribution utilities and regional transmission organizations should coordinate to validate grid edge resource aggregator registrations and market participation. It emphasizes processes for the utility to review and approve grid edge resource aggregation registrations—ensuring compliance with distribution tariffs, preventing double-counting with retail programs, and maintaining distribution grid reliability .
Ameren Missouri’s Response to Order Opening a Working Case Regarding FERC Order 2222 (Participation of grid edge resource Aggregators in RTO Markets
Component
Technical
Author
Filed by Ameren Missouri – signed by James B. Lowery (attorney, JBL Law) and Wendy K. Tatro (Director & Assistant General Counsel, Ameren) on behalf of the company
Stakeholder
Ameren Missouri (Union Electric Company) authored the response; it was part of Missouri PSC Case EW-2021-0267 (a Commission-led workshop on FERC Order 2222) . The issues discussed affect Missouri’s investor-owned utilities (Ameren and others like Evergy),
A utility-filed document in a Missouri Public Service Commission working case, detailing how retail rules and utility practices may need to adapt for grid edge resource aggregations. Ameren Missouri’s response emphasizes validation and compliance checks at the distribution level before grid edge resources can participate in wholesale markets. It raises consumer protection issues (e.g., requiring grid edge resource aggregators to register with the state and adhere to marketing standards to prevent fraud) . It discusses the need for enhanced metering and telemetry so that when a customer’s behind-the-meter resource provides wholesale services, the utility can measure those injections separately—ensuring retail billing credits (like net metering) and wholesale payments don’t overlap or double count the same energy . The filing also notes potential distribution infrastructure upgrades and operating procedures to maintain safety/reliability with aggregated grid edge resource dispatch (for instance, communication protocols for outage coordination and mechanisms for the utility to override or constrain aggregator dispatch for local grid safety). Overall, it outlines how the PSC should develop rules on interconnection, data sharing, dual participation, and dispute resolution between aggregators and utilities.