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Aggregators positioned to benefit from the regulation could include any company offering load management services to consumers, said R Street Associate Fellow Chris Villarreal, who cited leading rooftop solar and residential battery installer Sunrun Inc. as one example.
Unlike FERC’s landmark demand response rule, Order 2222 did not include a broad opt-out provision for states. However, the order did include a minor exemption for smaller utilities that distributed 4 million MWhs or less in the previous fiscal year.
While RTOs and ISOs have largely been tasked with crafting their own rules to comply with the rule, Villarreal maintained that state regulators also have a crucial role to play given that the order requires grid operators to work with states to agree on the data requirements necessary for DER aggregations to safely participate in wholesale markets.