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Pa. PUC Proposes Rules To Allow Aggregation Of DERs To Participate In PJM Wholesale Markets

December 18, 2025

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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The Pennsylvania PUC has published proposed rules which would govern the aggregation of distributed energy resources (DERs) for participation in PJM's wholesale markets

The proposed rules would require electric utilities with 100,000 or more customers to allow DER Aggregation Resource participation under two "narrow" conditions

Such proposed conditions are:

(1) customer-generators receiving service under the EDC’s net metering tariff are precluded from participating as a DER Aggregator Resource in the PJM capacity and energy markets. However, customer-generators may participate in the wholesale ancillary services markets as a DER Aggregator Resource as net metering customers do not provide ancillary services as part of their net metering participation

(2) the DER must have been approved by the EDC to participate as part of a Distributed Energy Resource Aggregator (DERA) in the energy, capacity and/or ancillary services markets.

Under the draft, a DER Aggregation Resource must be capable of satisfying a minimum energy and/or ancillary services market offer of 100 kW.

An individual DER included in an aggregation may not exceed 5 MW

Smaller EDCs may opt-in to allowing participation of DER Aggregations in the PJM wholesale markets

The PUC will allow EDCs to charge a fee for applications for a DER to participate in a DER aggregation. The PUC declined in the draft rules to propose a specific fee or any prescriptive requirements concerning the fee. The fee will be subject to PUC review via a tariff filing

Regarding data exchange between EDCs and DERAs, the PUC proposes to refer the matter and related subtopics to the Electronic Data Exchange Working Group (EDEWG).

However, the PUC does propose that utilities shall provide DERAs with access to the data of their individual DERs upon consent of the DER operator in a format approved by the PUC.

Several commenters had raised retail supplier-related issues in the rulemaking, or mechanisms similar to current retail market protocols, but the PUC did not not address any of these issues in the proposed rules (such as a DERA code of conduct)

Docket L-2023-3044115

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