Grid Coordination engages with regulators and standards bodies to promote an open, customer-centric architecture for the electrified grid. Our advocacy rests on three principles:
The grid was historically engineered around worst-case demand because real-time coordination with customer loads was impossible. Infrastructure was oversized; customer consumption was whatever it happened to be. That is no longer a fundamental constraint. IP networking, open grid-coordination protocols, and low-cost networked microcontrollers and single-board computers now make it practical to communicate dynamic prices and power limits to every flexible load in every home — and for those loads to respond autonomously on the customer’s behalf.
Regulation’s role is to ensure this new coordination layer stays open — so the capability benefits customers rather than entrenching proprietary lock-in.
Customers should control which devices they use and which services they delegate control to. A customer should be able to use the energy management system of their choosing to coordinate all the flexible loads in their home. No appliance manufacturer should be able to lock customers into proprietary control ecosystems.
Any control application should work with any appliance. A customer should be able to switch HVAC systems without changing their control interface, or switch energy management platforms without replacing their appliances. This requires open, standard protocols — not proprietary cloud integrations.
History shows that open standards in energy do not emerge from market forces alone. HVAC manufacturers have moved away from open control interfaces toward proprietary lock-in. By contrast, the water heater industry demonstrates what regulation can achieve: Washington and Oregon mandated the CTA-2045/EcoPort standard, and manufacturers responded by including it broadly — because supporting one standard SKU became cheaper than managing regional variants.
Open standards enforced through regulation create the conditions for innovation, competition, and customer benefit.
We have contributed formal responses to CEC proceedings on flexible demand standards:
Docket 24-FDAS-03 — Low-Voltage Thermostats: We advocated for broadening the scope beyond thermostats to encompass HVAC systems holistically, requiring open control protocols, and supporting (but not requiring) aggregators.
Docket 24-FDAS-04 — Electric Vehicle Supply Equipment: We advocated for customer choice and interoperability in EVSE standards, open protocol requirements for local and cloud control, V2X capability requirements, and user-configurable flexible demand servers.
The regulatory landscape in California is moving toward the grid coordination architecture we advocate:
| Driver | Significance |
|---|---|
| CalFUSE | CPUC’s California Flexible Unified Signal for Energy framework — a comprehensive policy roadmap for dynamic pricing and demand flexibility |
| CEC Load Management Standards | Requires large IOUs and CCAs to offer rates that change at least hourly by 2027 |
| CPUC Dynamic Hourly Rate Guidance | Directed PG&E, SCE, and SDG&E to design dynamic hourly retail rates by 2027 |
| CA AB 1787 | Requires post-2027 smart meters to provide customer access to usage data, linked to optional dynamic rate tariffs |
| CEC Flexible Demand Appliance Standards | CEC proceedings to define demand flexibility requirements for HVAC, EVSE, and other appliances |
These regulatory actions are converging on the architecture we describe in our Vision: dynamic pricing as the primary demand response mechanism, delivered through open standards, with local energy management systems optimizing autonomously on behalf of customers.