On December 4, 2012, the CPUC adopted Decision 12-11-025 (later amended by Decision 13-12-029) which set polies for the implementation of direct participation demand response.  In April 2014, the CPUC approved a set of rules that defined the roles and responsibilities of 3rd party demand response providers (DRPs), aggregators, utilities and customers in direct participation demand response.  These rules are also known as Electric Rule 24 (for Pacific Gas and Electric and Southern California Edison) and Rule 32 (for San Diego Gas and Electric).  This webpage provides more information on direct participation demand response and the utilities’ Rule 24/32.  


Q: What is Direct Participation DR?  

A: Direct Participation DR is a retail electric customer providing its ability to reduce some or all of its electric demand as a ‘bid’ in wholesale energy markets operated by the California Independent System Operator (CAISO).    Retail electric customers can bid on their own (if they meet all eligibility requirements) or rely on commercial entities known as “Demand Response Providers (DRPs) or aggregators” who aggregate retail customers into a single bid or multiple bids.  Bids that are accepted and dispatched by the CAISO will be awarded energy payments based on wholesale market prices.  Customers who participate through a DRP/aggregator will be paid according to the terms and conditions of any contractual agreement between themselves and their DRP/aggregator.  Customers should examine competing DRP services to find the one most appropriate to their situation.  Customers need to understand and agree upon how they will be compensated by their DRP/aggregator for their participation.  


Q: What is a Demand Response Provider (DRP) or aggregator? 

A: A DRP/aggregator is a commercial entity that provides demand response services such as assisting retail customers with strategies or technology to reduce their electric consumption and then providing the electric load reductions as a ‘bid’ in wholesale energy markets.  Some entities focus entirely on working with customers to reduce their electric consumption and paying incentives for their reductions.  Such entities are often referred to as “aggregators” and will have commercial arrangements with other entities that specialize in interfacing with the wholesale market.  The wholesale-facing entities are called Demand Response Providers (DRPs).  Some entities will handle both retail and wholesale transactions.  DRPs/aggregators who intend to solicit and serve utility bundled customers must register with the CPUC (more information about the registration process and a list of DRPs/aggregators with a valid CPUC registration is provided below). 

DRPs must also register at the CAISO, sign a Service Agreement with the CAISO, and meet all CAISO’s DRP requirements.  For the list of all DRPs registered at the CAISO, click here. 


Q: What are the CPUC rules on Direct Participation DR? 

A: The rules for Direct Participation DR can be found in Electric Rule 24 (for Pacific Gas and Electric & Southern California Edison) and Electric Rule 32 (for San Diego Gas & Electric), titled “Direct Participation Demand Response.”  DRPs/aggregators serving Direct Access (DA) or Community Choice Aggregation (CCA) customers are not subject to Rule 24/32. 

The CPUC adopted Rule 24/32 in accordance with CPUC decisions D.12-11-025, D.13-12-029, and CPUC Resolution E-4630.  In summary, Rule 24/32:  

  1. specifies the roles and responsibilities of different entities involved in facilitating direct participation DR, e.g., the utilities and DRPs/aggregators,   
  2. requires DRP service agreement with the utilities, 
  3. specifies meter data access requirements,  
  4. provides consumer protection, e.g., the requirements of DRP registration at the CPUC, customer notification letter, and performance bond; complaint resolution, and enforcement.   


Q: Where can I find Rule 24/32?  

A: PG&E’s and SCE’s Rule 24 and SDG&E’s Rule 32 can be found in the utilities’ websites: 


Q: Where can I find a list of DRPs/aggregators registered with the CPUC?  

A: All DRPs/aggregators enrolling utility bundled customers must have a valid registration with the CPUC and the CAISO prior to providing DR Service(s). 

  DRPs/aggregators who have registered with the CPUC will have their registration information listed on the Registered Demand Response Providers DRPs/Aggregators webpage. 


Q: What is the CPUC registration requirement for DRPs/aggregators?  

A: Any DRP/aggregator that enrolls the utilities’ bundled customers in Direct Participation Demand Response is required to register with the CPUC (and with CAISO).  As a part of the CPUC registration, DRP/aggregators serving residential and small commercial customers (defined as having a maximum peak demand of less than 20 kW) are also required to provide a performance bond and sample customer notification form letter to the CPUC. 

The utilities that provide their own demand response programs are not required to register with the CPUC since they are already regulated by the CPUC.  A customer operating as a DRP for its own demand response bidding into CAISO market is also not required to register with the CPUC.  DRPs/aggregators who enroll only Direct Access or Community Choice Aggregation customers are not required to register with the CPUC. 


Q: What must be provided to the CPUC for DRP/aggregator registration?  

A: The CPUC’s Energy Division handles all DRP/aggregator registration at the CPUC.  The following documents are required for the CPUC registration:    

1)   DRP Registration Form: 

To see sample click DRP Registration Form 

2)    An application fee of $100 via certified check (see DRP Registration Form for more details).

3)    Signed utility-DRP Service Agreements.  A service agreement is needed for each utility territory that the DRP intends to do business in:

4)    Performance bond.  If the DRP/aggregator intends to serve residential or small commercial customers (of less than 20 kW peak load), it must also provide a performance bond. The performance bond amount is based on the number of customers according to a formula in Rule 24/32 (Section E.1.d).  The minimum performance bond amount is $25,000. 

To see DRP Performance Bond Letter, click here: DRP Performance Bond Letter.

5)    Customer Notification Form Letter: Rule 24/32 (Section C.7) requires all DRPs/aggregators serving residential and small commercial customers to provide a letter that clearly explains the terms and conditions of the DR service contract.  The notification letter must be submitted to the CPUC as part of registration and must follow the format of the standard notification form letter found here: Direct Participation Customer Notification Letter  

An original with one hard copy and one electronic version, if applicable, of all documents must be submitted to: 

State of California 

Public Utilities Commission  

Energy Division – DRP Registration 

505 Van Ness Avenue

San Francisco, CA 94102



Q: Can a customer enroll with multiple DRPs or utility DR programs?   

A: Rule 24/32 (Section C.2.d) prohibits customer account registration with multiple DRPs at the CAISO for the same period.  Additionally a customer is prohibited from receiving demand response service with a DRP/aggregator while simultaneously participating in a utility demand response program.  A customer must notify its DRP of its intent to disenroll from its current DR Service or program prior to enrolling with another DRP or a utility for the same period.  


Similarly, prior to enrolling in a DR Service with a DRP/aggregator, the customer must disenroll from a utility demand response program. Disenrollment from a DRP/aggregator program or the utility DR program may be subject to contractual or program obligations with the DRP/aggregator or the utility.  DRPs/aggregators should take the time to familiarize themselves with any terms and conditions regarding disenrollment from a utility DR program. 


Q: What are the rules on meter data access?  

A: Accessing customer’s meter data is a critical requirement for direct participation DR.  All DRPs/aggregators must obtain customer approval in order to access the customer’s electric usage data and other personal information regarding the customer’s service account.  The customer’s consent is provided through its utility’s Authorization or Revocation of Authorization to Disclose Customer Information to a Demand Response Provider under Rule 24/32 (CISR-DRP) form or other electronic means, if available.    

CISR-DRP forms can be found here: 


The customer may obtain the CISR-DRP form from its utility or DRP/aggregator. The CISR-DRP form also allows the customer to revoke, at any time, any previously granted authorization, subject to any early termination provisions specified in the contract between the DRP/aggregator and customer.    

The CISR-DRP form provides the customer with options to authorize its DRP/aggregator to access to meter data, including for a specified period of time or indefinitely, until revoked by the customer.  If the customer makes no election, its utility will assume that the customer authorization is for an indefinite period of time (per CPUC Resolution E-4599). With customer permission, its DRP/aggregator may also act as its agent to automatically revoke data transmittal on the customer’s behalf upon disenrollment from DR Service.   

It is important to know that when discontinuing DR Service with a DRP/aggregator, it will be the customer’s responsibility to REVOKE authorization to STOP the transmittal of its energy usage data and other previously authorized personal information from its utility to the DRP/aggregator. 


Q: What are the CPUC’s rules on customer privacy?  

A: Once a customer authorizes disclosure of its energy usage data and other personal information to a DRP/aggregator, the DRP/aggregator is required to maintain the privacy and security of that data, subject to the Commission’s privacy policies. The CPUC’s privacy policies can be found in Decisions (D.)11-07-056  


Q: What if a customer has a complaint against a DRP/aggregator or the utility?  What can they do?    

A: Customers have the option to file a complaint or action at the appropriate civil court or agency. They may also file a formal complaint, informal complaint, or seek alternate dispute resolution (ADR) at the CPUC regarding the DR Services. 

Informal Complaint:  

Send a written complaint to:  

Consumer Affairs Branch  

California Public Utilities Commission  

505 Van Ness Avenue  

San Francisco, CA 94102 


Submit a written complaint online here: File a complaint.  


Call 800-649-7570 (toll free) or 415-703-4973  

TDD for speech and hearing impaired call 800-229-6846 (statewide).  

Public telephone hours are between 8:30 a.m. and 4:30 p.m. 


Formal Complaint:  

Through the Formal Complaint procedure, the Commission can order the DRP to take corrective action, including reimbursements for non-payment of performance.  It is important to note, however, that the Commission is not allowed to award damages for such things as personal injury, property damage, emotional distress, or loss of wages or profits. To request compensation for damages, the customer must file a claim in a civil court.  


Privacy Notice 

Whether or not a Formal Complaint is filed in paper form or electronically, Formal Complaints filed with the Commission become a public record and may be posted on the CPUC’s website. Therefore, any information provided in the Formal Complaint, including, but not limited to, the filer’s name, address, city, state, zip code, telephone number, email address and the facts of the case may be available on-line for later public viewing.  

A formal complaint must be filed at the Commission. If you need help with or have any questions about filing your formal complaint, contact CPUC’s Public Advisor's Office.  


The Public Advisor-CPUC  

505 Van Ness Avenue  

San Francisco, CA 94102  

866-849-8390 (toll free)  



Public Advisors Office  


Q: What is Alternative Dispute Resolution Program (ADR)? 

A:ADR commonly describes processes, such as facilitation, negotiation, mediation, and early neutral evaluation to help disputants resolve a conflict without a formal decision by a court or agency. When successful, ADR may achieve results that a court or agency could not order, give the parties more ownership in the result, and reduce litigation and agency costs. 

The Administrative Law Judge (ALJ) Division administers the ADR program and trained, experienced ALJs serve as neutrals in the program. 

ADR can occur at any time during a formal proceeding.  The early use of ADR saves parties time and money and avoids unnecessary escalation of a dispute. On occasion, ADR may be available to help resolve disputes that are still informal and have yet to be filed as formal complaints. Most ADR sessions are completed in ½ to 2 days. Some ADR sessions continue over several weeks, with the parties meeting for a day or two at a time. 

For additional information visit Alternative Dispute Resolution (ADR). 

Useful Contact Information: 

California Public Utilities Commission 

Consumer Affairs Branch Hotline 

505 Van Ness Avenue 

San Francisco, CA 94102 

Call 800-649-7570 (toll free) or 415-703-4973  


Energy Division