Aggregator / DRP FAQ

Information in this FAQ for the San Diego Gas & Electric^® (SDG&E^®) Emergency Load Reduction Program (ELRP) may change, in whole or in part, subject to California Public Utilities Commission (CPUC) approval.

General Questions

What is ELRP?

The Emergency Load Reduction Program (ELRP) is a seven-year pilot program administered by San Diego Gas & Electric^® that offers participants financial incentives to reduce energy usage or export energy during times of high grid stress and emergencies, with the goal of avoiding rotating outages. Participants earn $2 per kilowatt-hour (kWh) reduced during ELRP events.

Unlike other demand response programs, ELRP allows for limited dual participation for customers enrolled in SDG&E’s Critical Peak Pricing (CPP), Capacity Bidding Program (CBP), and with third-party demand response providers (DRPs). 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.
I have seen references to ELRP group numbers (A.1, A.2, B.1, etc.). What are those?
Eligible participants for the ELRP are divided into two groups, each with multiple subgroups.

Group A includes customers and aggregators not participating in market-integrated supply side Demand Response (DR) programs.

Group A is comprised of:

Non-residential aggregators (A.2)

Virtual power plant aggregators (A.4)

Electric Vehicle and Vehicle-grid Integration aggregators (A.5)

Group B includes market-integrated supply side proxy demand resources (PDRs).

Group B is comprised of:

Third-party DRPs (B.1)

SDG&E’s CBP aggregators (B.2)
Am I eligible for the ELRP?
CBP aggregators and third-party DRPs with market-integrated PDRs, are eligible to participate in ELRP. In addition, there are several non-market-integrated subgroups that are available to aggregators.

VPP aggregators managing behind-the-meter storage paired with net energy metering solar and/or stand-alone storage deployed with bundled or unbundled non-residential customers, whose virtual power plants meet 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 DR program.

All sites in the aggregation are located in SDG&E’s service territory.

The virtual power plant’s aggregated behind-the-meter storage capacity meets or exceeds 500 kW; 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 in the aggregation has a Rule 21 permit and operates in a manner compliant with existing rules and tariffs applicable to the site.

VGI aggregators managing an aggregation consisting of any combination of electric vehicles and charging stations, including those capable of managed one-way charging (V1G) and bi-directional charging and discharging (V2G), deployed with bundled or unbundled non-residential customers that meet 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 DR program.

All sites in the aggregation are located in SDG&E’s service territory.

The aggregation is able to contribute 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)

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 market-integrated DR program.

All sites in the aggregation are located in SDG&E’s service territory.

The aggregated resource capacity meets or exceeds 500 kW.
Who is Olivine?

Program Questions

How will the ELRP help in times of grid emergencies?

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 (CAISO) grid reliability needs and will not be used for localized grid needs (i.e., transmission and distribution) by SDG&E.
What are the benefits of participating in the ELRP?
Is the use of prohibited resources to respond to an ELRP event permitted?
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.
Although prohibited resources may be used by eligible non-residential participants to respond to ELRP events (when permitted by a Governor’s Executive Order and in compliance with Rule 21 and other applicable regulations and permits), it is important to note that stationary back-up generators are often subject to air district requirements, which vary by air district and may include permitting requirements, emission limits, and operational restrictions. ELRP participants are solely responsible for all environmental and other regulatory requirements associated with operating their prohibited resources.
Review the CalEnviroScreen Disadvantaged Communities Map to see the areas classified as disadvantaged communities.
The following list of back-up generation resources are defined as prohibited in either topping cycle Combined Heat and Power or non-Combined Heat and Power configuration:
Diesel powered distributed generation technologies
Natural gas
Gasoline
Propane
Liquefied petroleum gas
The use of Prohibited Resources during a test event is not permitted and should not be compensated.
Can I export energy during an ELRP event?
What is the term of the ELRP?

The ELRP was ordered by the California Public Utilities Commission (CPUC) 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 SDG&E to implement the ELRP by May 1, 2021. Subsequent Decisions 21-06-027, D.21-12-015 and D.23.12.005 made modifications to the ELRP. The ELRP program has been approved through 2027.
What is the term of my commitment to the ELRP?

Enrollment Questions

How do I enroll my customers?
Interested aggregators and third-party demand response providers may email [email protected] to initiate their enrollment. SDG&E also offers a service provider option for virtual power plant aggregations and vehicle-grid-integration aggregations. Please contact [email protected] for more information.

Virtual Power Plant, Vehicle Grid Integration, and other non-Residential Aggregators must do the following before enrolling their aggregations in the ELRP:

Review and electronically sign the Aggregator Agreement to accept the applicable terms and conditions

Execute and submit an Add / Delete form for each customer in the aggregation, including customer signature

Complete and submit an Add / Delete spreadsheet

Provide an aggregated load-reduction nomination for the aggregation

Capacity Bidding Program Aggregators must do the following before enrolling their aggregations in ELRP:

Review and electronically sign the Participation Agreement to accept the applicable terms and conditions

Provide an aggregated load-reduction nomination for each resource

Third-Party Demand Response Providers must do the following for their aggregation(s) to participate in ELRP:

Review and electronically sign the Participation Agreement to accept the applicable terms and conditions

Provide an aggregated load-reduction nomination for each resource

Note that Third-Party Demand Response Providers do not need to sign a Participation Agreement prior to participating in events, but must sign one prior to invoicing.

A nomination is the estimated incremental load reduction quantity (kW) for an event. Additionally, aggregators and third-party demand response providers must provide information such as the location (account number and meter number), 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.
What are the Terms and Conditions?
What is the ELRP Aggregator Agreement?
What is a nomination in the ELRP?

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 from exceeding the nomination. Nominations are utilized to estimate the total expected load reduction. All aggregators are required to provide aggregated load reduction nominations. Aggregators may update their nominations at any time by emailing [email protected].
Can I virtually aggregate electrically contiguous sites?

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 SDG&E on a case-by-case basis.
If you are interested in virtually aggregating electrically contiguous sites, please email [email protected] indicating that you are interested in virtually aggregating electrically contiguous sites. The ELRP team will follow up with you with more information.
How can I unenroll my aggregation?

Questions about ELRP Events

When will an event be scheduled?
What does an email event notification look like?

See below for a sample email event notification. An email event notification will include the aggregator name, date and time of the event. Note that the exact email text may differ based on the participant and the subgroup in which they are enrolled. For example, event notifications for CBP aggregators and third-party demand response providers will state they are courtesy notifications.

Email event notifications will be sent from [email protected].
What happens if I don’t respond to an event?
How many times will I be called to respond to an event?
The annual dispatch limit is 60 hours per year. The ELRP program availability is from May 1 through October 31 each year, seven days a week, from 4 p.m. – 9 p.m. Events may be called on consecutive days, depending on grid conditions, and durations vary by subgroup as follows:

Subgroups A1, A2, A3, B1, B2: 1-5 hours

Subgroups A4, A5: 1-3 hours
When will I be notified of an event?

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 after the CAISO notice is issued.
Virtual power plant, vehicle-grid-integration, and non-residential aggregations have minimum dispatch hours and may be notified day-ahead or day-of in response to forecasted or anticipated grid stress conditions, such as high locational marginal prices in the CAISO markets and extreme heat waves, to achieve the minimum dispatch hours.
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 CAISO notices themselves if they plan to participate.
How will I be notified of an ELRP event for my aggregation?

Aggregators and third-party demand response providers will be notified of events by email and, if they choose, text (SMS). 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 that Capacity Bidding Program aggregators and third-party demand response providers are solely responsible for monitoring CAISO notices themselves if they plan to participate.

Aggregators and third-party demand response providers are responsible for notifying their customers of events.

If you are interested in receiving event notifications via OpenADR or any of Olivine’s other dispatch APIs, contact Olivine at [email protected].
Are there minimum dispatch hours for the event season?

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. There are no minimum dispatch hours for any other aggregator subgroup.
Are there test events?

Questions about Payments

How much money will I earn?
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 CBP Energy payments for any portion of the load reduction counted in the ILR. The ILR is calculated by subtracting the CBP nomination from the CBP aggregation’s ELRP event performance.
The ELRP baseline used to calculated ELRP Event Performance is determined by modifying the applicable CAISO 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 CBP program events 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 +/- 40%
For more information on the performance and incentive calculations, reference section 4 of the Group B Terms and Conditions.
How are performance payments calculated (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 CAISO market payments for any portion of the load reduction counted in the ILR and the CAISO Opportunistic Revenue. The ILR is calculated by subtracting the CAISO (CAISO) 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 calculated ELRP Event Performance is determined by modifying the applicable CAISO 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 CAISO 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 4 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.
The baseline specified in section 6 of the Group A Terms and Conditions will be utilized, accounting for any applicable special conditions described in section 6.
Can submetered data be used to calculate event performance?

The use of submetered data for event performance calculations is permitted for virtual power plant and vehicle-grid-integration aggregators. The use of submetered data will be approved by SDG&E on a case-by-case basis. Aggregators that elect to use submeter data for settlement purposes shall also comply with approved submetering services as outlined in the Aggregator Agreement. The election to utilize submetering will apply to all locations within the aggregation. If the third party is an aggregator, they must provide a single value for each interval, aggregating before sending it to SDG&E for settlement calculations. SDG&E may ask for individual submeter data for pilot Monitoring and Evaluation (M&E) purposes. During the aggregator enrollment process, the aggregator needs to choose if the event performance will be calculated at the SDG&E meter or submeter, which cannot be changed until the next calendar year.
How and when will I get paid?

Group A Aggregators: 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.

Capacity Bidding Program aggregators will receive payments for this program through the same process that Capacity Bidding Program and Base Interruptible Program payments are made.

Third-party demand response providers who provide an invoice will be paid by check. SDG&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 a resolution to SDG&E’s satisfaction.
What information is required for an ELRP Group B Demand Response Provider invoice?

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 the May-June-July period by September 30, and for the August-September-October period by December 31 of the program year. To request the most recent version of the Third Party DRP Invoice Template and submission instructions, please send an email to [email protected]. 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, CAISO market event performance, day ahead and real time market prices, incremental load reduction (ILR), applicable market awards during the event, applicable CAISO market payments for load reductions counted in the ILR, and ELRP Event Compensation.

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