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.

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.

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.