Aggregator / DRP FAQ
The information provided in this ELRP Aggregator / Demand Response Provider FAQ can change in whole or in part subject to California Public Utilities Commission approval.
The Emergency Load Reduction Program (ELRP) is a 5-year pilot administered by PG&E that offers participants financial incentives to reduce energy usage or export energy during times of high grid stress and emergencies.
The ELRP was ordered by the California Public Utilities Commission in rulemaking 20-11-003, Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Reliable Electric Service in California in the Event of an Extreme Weather Event in 2021. Specifically, Decision 21-03-056 laid out the requirements for PG&E to implement the ELRP by May 1, 2021. Subsequent Decisions 21-06-027 and 21-12-015 made modifications to the ELRP.
Unlike other demand response programs, ELRP allows for dual participation for customers enrolled in Peak Day Pricing Program, Base Interruptible Program, Capacity Bidding Program, and with third-party demand response providers. In addition, this program is unique in its voluntary nature as there are no penalties for non-performance. For customers capable of export, the program incentivizes the export of energy for participants with a behind-the-meter Rule 21-interconnected device with an existing Rule 21 export permit.
Eligible participants for the ELRP are divided into two groups, each with multiple subgroups. Group A includes customers and aggregators not participating in Demand Response programs. Group B includes market-integrated proxy demand resources.
Group A is comprised of:
- Non-residential, non-demand response customers (A.1).
- Non-residential aggregators (A.2).
- Rule 21 exporting distributed energy resources (A.3).
- Virtual power plant aggregators (A.4).
- Electric Vehicle and Vehicle-grid-integration aggregators (A.5).
- Residential customers (A.6) – Power Saver Rewards. For more information about Power Saver Rewards, go to powersaver.pge.com.
Group B is comprised of:
- Third-party demand response providers (B.1).
- PG&E’s Capacity Bidding Program aggregators (B.2).
Olivine, Inc. is the Program Implementer for PG&E’s ELRP and provides the infrastructure and program management for the pilot. Olivine is a California-based company focused on helping the state meet its ambitious renewable energy and greenhouse gas reduction goals. Olivine has a proven track record in undertaking complex utility programs. To learn more about Olivine, please visit www.olivineinc.com
Base Interruptible Program aggregators, Capacity Bidding Program aggregators and third-party demand response providers with a market-integrated Proxy Demand Resource are eligible to participate in the program.
Virtual power plant aggregators managing behind-the-meter storage paired with net energy metering solar and/or stand-alone storage deployed with bundled or unbundled residential and/or non-residential customers, whose virtual power plant meets the following criteria, are eligible to participate in the program:
- The virtual power plant or any site within the aggregation is not simultaneously enrolled in a market-integrated demand response program.
- All sites within the aggregation are located within PG&E’s service territory.
- The aggregated behind-the-meter storage capacity of the virtual power plant meets or exceeds 500 kW; the virtual power plant size is determined by the summation of the Rule 21 interconnected capacity of the individual storage devices comprising the aggregation.
- Each site within the aggregation has a Rule 21 permit and operates in a manner compliant with existing rules and tariffs applicable to the site.
Vehicle-grid-integration aggregators consisting of any combination of electric vehicles and charging stations – including those that are capable of managed one-way charging (V1G) and bi-directional charging and discharging (V2G) deployed with bundled or unbundled residential and/or non-residential customers that meets the following criteria – are eligible to participate in the program:
- The aggregation or any customer site within the aggregation is not simultaneously enrolled in a market-integrated, supply-side demand response program.
- All sites within the aggregation are located within PG&E’s service territory.
- The aggregation can contribute Incremental Load Reduction (ILR) equal to or greater than 25 kW for a minimum of one hour during an ELRP event.
- All sites within the VGI aggregation have operational electric vehicle supply equipment (EVSE).
- Sites within the VGI aggregation that intend to implement V2G must have UL 1741 SA4* certification, any subsequent UL 1741 supplement certification as required in Rule 21 or Smart Inverter Working-Group recommended smart inverter functions and satisfies all other Rule 21 interconnection requirements.
*Direct Current (DC) V2G EVSE that have UL 1741 certification, but not UL 1741 SA, may interconnect initially for the purposes of participating in the ELRP, subject to remaining Rule 21 interconnection requirements. PG&E reserves the right to terminate this exception after the 2024 ELRP season via a Tier 2 Advice Letter filing. Termination of this pathway would not affect previously interconnected EVSE.
All other non-residential aggregators with aggregated bundled or unbundled non-residential customer resources meeting the following criteria are eligible to participate in the program:
- The aggregated resource or any site within the aggregation is not simultaneously enrolled in a supply-side demand response program
- All sites within the aggregation are located within PG&E’s service territory
- The aggregated resource capacity meets or exceeds 500 kW
Participants in the ELRP will reduce energy usage during times of high grid stress and emergencies, with the goal of avoiding rotating power outages while minimizing costs to customers. The ELRP is to be utilized for system-wide California Independent System Operator grid reliability needs and will not be used for localized grid needs (i.e., transmission and distribution) by PG&E.
The ELRP duration will be five years (2021-2025).
If the service agreement is in a disadvantaged community, a participant may not use back-up generation to achieve incremental load reduction if the back-up generation is designated as a Prohibited Resource per California Public Utilities Commission Resolution E-4906. If the service agreement is not located in a disadvantaged community, the participant may only utilize the prohibited resource to achieve incremental load reduction during an ELRP event when permitted by a Governor’s Executive Order and in compliance with Rule 21 and other applicable regulations and permits, including those imposed by the local air district.
Participants dually enrolled in another demand response program may use prohibited resources during an overlapping event period but only for achieving incremental load reduction below any existing commitments when permitted by a Governor’s Executive Order and if they are not in a disadvantaged community.
The following list of resources are defined as prohibited in either topping cycle Combined Heat and Power or non-Combined Heat and Power configuration:
- Distributed generation technologies using diesel
- Natural gas
- Liquefied petroleum gas
Review the CalEnviroScreen Disadvantaged Communities Map to see the areas classified as disadvantaged communities.
The use of Prohibited Resources during a test event is not permitted and should not be compensated.
If a site has a behind-the-meter Rule 21 interconnected device with export capability and permit and the participant specifies they want to be compensated for exports, exported energy will be counted in the load reduction.
In addition to helping avoid rotating power outages, aggregators and demand response providers (DRPs) can earn $2/kWh of incremental load reduction below any existing commitments during ELRP events. Note that Base Interruptible Program aggregators are only eligible for ELRP compensation for ELRP events that overlap with Base Interruptible Program events and only the incremental reduction below the Base Interruptible Program pre-committed Firm Service Level during the overlapping event window is compensated under the ELRP.
Aggregators and third-party demand response providers must remain enrolled in the ELRP for the duration of the season (May through October).
What is the difference between direct enrollment vs. enrollment through an Aggregator/Third-Party Demand Response Provider?
Direct enrollment refers to customers that initiate and complete the ELRP enrollment process directly with PG&E. Reference the General Questions section of the Customer FAQ for direct enrollment eligibility requirements. Direct enrolled customers will receive notifications and any payments directly from the program. Customers enrolled through aggregators and third-party demand response providers will receive notifications and any payments from the aggregator or third-party demand response provider.
If you are enrolled with an aggregator or third-party demand response provider, please contact them for information about the program. Note that if you are enrolled in the Base Interruptible Program through an aggregator, your aggregator has the first option to enroll you in the program. If they choose not to enroll in the program, you may enroll directly.
Interested aggregators and third-party demand response providers may email email@example.com to initiate their enrollment. PG&E also offers a service provider option for virtual power plant aggregations and vehicle-grid-integration aggregations. Please contact firstname.lastname@example.org for more information.
Aggregators and third-party demand response providers must review and electronically sign the required agreement(s), agreeing to the applicable terms and conditions. New aggregators to PG&E programs must also sign the Aggregator Agreement and utilize the Add / Delete form for customers they intend to enroll in the program.
Aggregators and third-party demand response providers must provide the location (address), type of fuel used, nameplate capacity, notice time, and ramp time for all back-up generators within their aggregations before they can receive compensation for event participation. Additionally, aggregators and third-party demand response providers are required to provide aggregated load-reduction nominations. Base Interruptible Program nominations must be provided by sub-LAP. A nomination is the estimated incremental load reduction quantity (kW) for an event.
Base Interruptible Program aggregators have priority over their customers to enroll in the ELRP and have until April 15 of the program year to affirm intent to participate in the ELRP. Base Interruptible Program aggregators are asked to complete enrollment by April 30 of the program year. Note these enrollment dates do not apply to the other aggregator participation options.
Third-party demand response providers must sign the agreement prior to submitting an invoice to PG&E. Courtesy ELRP event notifications are available to third-party demand response providers who have signed the agreement.
The Terms and Conditions for Base Interruptible Program, virtual power plant, vehicle-grid-integration and other non-residential aggregators are available here:
The Terms and Conditions for Capacity Bidding Program aggregators and third-party demand response providers are available here:
A nomination is the estimated target load reduction quantity (kW) for an ELRP event. Participation in ELRP events is entirely voluntary and no financial penalties will result from not meeting or exceeding the nomination. Nominations are utilized to estimate the total expected load reduction. Aggregators and demand response providers are required to provide load-reduction nominations. Base Interruptible Program aggregators are required to provide load reduction nominations by sub-LAP and the nomination should be aggregate incremental load reduction below the aggregate Firm Service Level. Aggregators may update their nominations at any time by emailing email@example.com.
The use of a virtual aggregation may be elected by a vehicle-grid-integration aggregator at the time of enrollment. Only during ELRP dispatch hours, a customer with control over multiple electrically contiguous sites is permitted to virtually aggregate the load and generation to fully utilize the sum of the net export allowed by any Rule 21 permit(s) associated with the sites. Two sites are considered electrically contiguous when they have electric service derived from the same utility distribution transformer secondary and there are no devices on the utility distribution system that can interrupt power flow to only one site. Virtual aggregation applications will be reviewed and approved by PG&E on a case-by-case basis.
If you are interested in virtually aggregating electrically contiguous sites, please send an email to firstname.lastname@example.org to indicate that you are interested in virtually aggregating electrically contiguous sites. The ELRP team will follow up with you with more information.
Aggregators and third-party demand response providers (DRPs) have until April 15 of the program year to send written notice to email@example.com of their request to disenroll, otherwise they remain enrolled for the duration of the season. The termination will become effective within 30 days after the written notice is received.
Questions about ELRP Events
ELRP events are triggered by the “Energy Emergency Alert (EEA)” defined by the California Independent System Operator Operating Procedure 4420.
Day-Ahead events are triggered by EEA Watch notices. Day-Of events are triggered by EEA Watch and EEA 1, 2 or 3 notices. Base Interruptible Program participants are only eligible for ELRP compensation for ELRP events that overlap with Base Interruptible Program events and only the incremental reduction below the Base Interruptible Program pre-committed Firm Service Level is compensated under the ELRP.
See below for a sample email event notification. An email event notification will include the sites you have enrolled in the ELRP and the date and time of the event. Note that the exact email text may differ based on the participant and subgroup in which they are enrolled. For example, the event notification for directly enrolled Base Interruptible Program customers and aggregators will include a reminder that Base Interruptible Program participants are only compensated for ELRP events that overlap with Base Interruptible Program events. Additionally, event notifications for Capacity Bidding Program aggregators and third-party demand response providers will state they are courtesy notifications.
Email event notifications will be sent from firstname.lastname@example.org.
Participation in ELRP events is entirely voluntary and no financial penalties will result from not meeting or exceeding the nominated target.
The annual dispatch limit is up to 60 hours per year. The ELRP program availability is from May through October each year, seven days a week, from 4 p.m. to 9 p.m. Events can last anywhere from one hour to five hours and may be called on consecutive days, dependent on grid conditions.
If an ELRP event or dispatch does not occur during the season, PG&E will conduct one test event, with a two-hour duration, per year for directly enrolled customers. Directly enrolled customers, except for those relying exclusively on prohibited resources, are required to participate in the test events. Use of prohibited resources during a test event is not permitted and will not be compensated. Load reduction delivered during an ELRP test event is eligible for ELRP compensation.
Notifications for Day-Ahead events will be sent generally by 5 p.m. via email and/or text the day before the event occurs. Notifications for Day-Of Events will be sent shortly after the California Independent System Operator notice is issued.
Virtual power plant, vehicle-grid-integration, and non-residential aggregations may have additional program triggers in response to forecasted or anticipated grid stress conditions.
Capacity Bidding Program aggregator and third-party demand response provider notifications are courtesy notifications. Capacity Bidding Program aggregator and third-party demand response providers are solely responsible for monitoring California Independent System Operator notices themselves if they plan to participate.
Aggregators and third-party demand response providers will be notified of events by email and/or text. Note that Capacity Bidding Program aggregator and third-party demand response provider notifications are courtesy notifications. Only third-party demand response providers that have affirmed their intent to participate in the ELRP, by agreeing to the Terms and Conditions and providing contact information for notifications, prior to the event will receive these courtesy notifications. Note Capacity Bidding Program aggregators and third-party demand response providers are solely responsible for monitoring California Independent System Operator notices themselves if they plan to participate.
Aggregators and third-party demand response providers are responsible for notifying their customers of events. Note Base Interruptible Program aggregators may want to notify their customers of only ELRP events that overlap with Base Interruptible Program events and may want to restrict any ELRP specific dispatches to the overlapping event window.
If you are interested in receiving event notifications via OpenADR or any of Olivine’s other dispatch APIs, contact Olivine at email@example.com.
For non-residential aggregators, the Minimum Aggregation Dispatch Hours are set at 10 hours per season. For virtual power plant aggregators, the Minimum Aggregation Dispatch Hours are set at 20 hours per season. For vehicle-grid-integration aggregators, the Minimum Aggregation Dispatch hours are set at 30 hours per season.
Questions about Payments
Aggregators can earn $2/kWh of incremental load reduction beyond any existing commitments during ELRP events.
Base Interruptible Program aggregator performance payments are calculated at the sub-LAP level by multiplying the incremental load reduction (ILR) by the Energy Compensation Rate, which is set at $2/kWh.
The ILR for Base Interruptible Program aggregations is calculated at the sub-LAP level by subtracting the aggregate load during the overlapping event window from the aggregate pre-committed Firm Service Level.
Base Interruptible Program participants are only eligible for ELRP compensation for ELRP events that overlap with Base Interruptible Program events and only the incremental reduction below the Base Interruptible Program pre-committed Firm Service Level during the overlapping event window is compensated under ELRP.
How are performance payments calculated (Capacity Bidding Program aggregators & third-party Demand Response Providers)?
Compensation for load reduction delivered during an ELRP event is determined by multiplying the Incremental Load Reduction (ILR) by $2/kWh, then subtracting any California Independent System Operator market payments for any portion of the load reduction counted in the ILR and the California Independent System Operator Opportunistic Revenue. The ILR is calculated by subtracting the California Independent System Operator scheduled award quantities, inclusive of day-ahead market (DAM) and real-time market (RTM), from the Proxy Demand Resource’s ELRP event performance.
The ELRP baseline used to calculate ELRP Event Performance is determined by modifying the applicable California Independent System Operator baseline to account for the following:
- Count net exports to the distribution grid by customer locations within the Proxy Demand Resource aggregation that comply with Rule 21 and other applicable permits
- Exclude prior days with other ELRP events when selecting the set of “non-event, but similar” days when calculating the baseline
- Exclude applicable preceding hours with either California Independent System Operator market awards or another ELRP event on the day of the ELRP event when calculating the same-day adjustment (SDA) to the calculated baseline in step 2
- Allow the SDA in step 3 to +/- 100%
For more information on the performance and incentive calculations, reference section 3 of the Group B Terms and Conditions.
How are performance payments calculated (Virtual power plants, Vehicle-grid-integration, and other non-residential aggregators)?
ELRP performance and payments are calculated for aggregators at the aggregate level. ELRP compensation for load reduction delivered during an event is determined by multiplying the aggregate Incremental Load Reduction (ILR) by $2/kWh. The ILR is the aggregate baseline minus the aggregate net energy.
For virtual power plant aggregators, the aggregator selected California Public Utilities Commission approved baseline for PG&E’s Capacity Bidding Program is utilized and modified to account for exported energy, to the extent allowed by a site’s Rule 21 export permit, during non-event days and count exported energy in ILR.
For vehicle-grid-integration aggregators and other non-residential aggregators, the baseline specified in section 188.8.131.52 of the Group A Terms & Conditions will be utilized, accounting for any applicable special conditions described in section 184.108.40.206.
The use of sub-metered data for event performance calculations is permitted for virtual power plant and vehicle-grid-integration aggregators. The use of sub-metered data will be approved by PG&E on a case-by-case basis. Aggregators that elect to use sub-meter data for settlement purposes shall also comply with approved submetering services as outlined in the Aggregator Agreement. The election to utilize sub-metering will apply to all locations within the aggregation. During the aggregator enrollment process, the aggregator needs to choose if the event performance will be calculated at the PG&E meter or sub-meter, which cannot be changed until the next calendar year.
Third-party demand response providers who provide an invoice will be paid by check. PG&E will settle invoices within 60 days of the invoice date absent the need for additional information, which would set the 60 days from the time all additional information is received in order to process the invoice. In case of an audit, the 60-day period is frozen until there is resolution to PG&E’s satisfaction.
Capacity Bidding Program and Base Interruptible Program aggregators will receive payments for this program through the same process that Capacity Bidding Program and Base Interruptible Program payments are made, respectively. Virtual power plant, vehicle-grid-integration, and other non-residential aggregators will be paid by check. Aggregators will receive compensation for the ELRP season by March 1 of the following year.
To receive ELRP compensation, the third-party demand response provider shall submit an aggregate invoice for the Cumulative Portfolio Level Net Event Compensation of each Proxy Demand Resource Portfolio for May-June-July period by September 30 and for August-September-October period by December 31 of the program year to PG&E’s Demand Response Auction Mechanism team at ELRPB1@pge.com. Participating third-party demand response providers will be provided with a template for ELRP demand response provider invoices. The Cumulative Portfolio Level Net Event Compensation of a Proxy Demand Resource Portfolio over one period is determined by summing the Portfolio Level Net Event Compensation across all ELRP events in that period.
The invoice shall be accompanied with the supporting data for each event, including but not limited to Proxy Demand Resource-specific ELRP Event Performance, California Independent System Operator market event performance, day ahead and real time market prices, incremental load reduction (ILR), applicable market awards during the event, applicable California Independent System Operator market payments for load reductions counted in the ILR, and ELRP Event Compensation.