Who Owns the Virtual Power Plant

New Orleans City Council voted unanimously to spend $30 million installing solar and battery systems in approximately 1,500 homes and 250 community institutions. The same week, Rivian made its electric vehicles available as controllable grid resources across more than 70 utilities through EnergyHub’s platform. Illinois began enrolling commercial aggregators for the first virtual power plants in PJM territory. And Minnesota regulators started weighing whether Xcel Energy should be allowed to own distributed batteries outright.

These are four programs with four ownership structures and no consensus on a single question: who controls the grid behind the meter.

The settlement model. New Orleans is funding its virtual power plant, called the Neighborhood Power Plan, entirely from an Entergy nuclear plant settlement. No ratepayer dollars are involved. Forty percent of residential funding is reserved for low-to-moderate income households. Implementation begins in 2026 with a three-year rollout plan to be filed by March 1. Entergy retains its distribution wires. Customers retain their solar and battery systems. A third-party platform orchestrates dispatch. The utility’s role is reduced to settlement check-writer.

The structure is notable for what it avoids. There is no utility rate case, no capital expenditure filing, no regulatory proceeding beyond the council vote. The program is sized to function as distributed generation and storage capacity that requires no gas, no new transmission, and no utility balance sheet involvement.

The aggregator model. Illinois is taking a different path. Under the 2025 Clean and Reliable Grid Affordability Act, ComEd will begin enrolling third-party aggregators this spring to bid customer-owned distributed energy resources into PJM’s capacity market. Participating customers receive upfront enrollment rebates and annual participation payments. The system-wide benefit flows through reduced forward capacity auction costs beginning with the 2029-2030 delivery year. Aggregators, not the utility and not individual customers, manage the portfolio and capture the spread between customer payments and capacity market revenue.

The Illinois model represents a structural bet that competitive aggregation will drive faster enrollment and better optimization than utility-managed alternatives. It is among the first aggregator-led VPP programs in PJM territory, a market where capacity prices reached a record $333 per megawatt-day in the most recent auction.

The utility model. Minnesota presents the inverse. Xcel Energy’s Capacity*Connect proposal asks the state’s Public Utilities Commission to let the utility own and operate distributed battery systems directly, bypassing third-party aggregators and customer ownership entirely. The commission is expected to rule by mid-2026. If Xcel prevails, utilities across the country will have a template for owning the distributed grid rather than merely interconnecting it. If it loses, the aggregator model gains precedent.

The Minnesota proceeding carries weight beyond a single state. Utility commissions in at least a dozen states are watching the outcome to inform their own distributed energy frameworks. The question is not whether virtual power plants will scale, but whether incumbent utilities or competitive entrants will operate them.

The platform model. Rivian and EnergyHub represent a fourth architecture. Rather than stationary batteries dispatched for peak shaving or capacity bids, this partnership makes electric vehicles available as controllable grid resources through EnergyHub’s distributed energy resource management platform. The integration enables dynamic load shaping, coordinating EV charging during off-peak hours and periods of renewable energy abundance, and adds Rivian to EnergyHub’s broader ecosystem alongside thermostats, batteries, and other flexible devices. No battery incentive is required. No capacity market bid is placed. Value accrues to the utility through avoided infrastructure investment, and to drivers through participation payments.

The common denominator. EnergyHub appears in two of these four stories: orchestrating New Orleans’ settlement-funded solar and battery systems and integrating Rivian’s vehicle fleet across more than 70 utility territories. The company is positioning its DERMS platform as an operating system that works across ownership models, collecting orchestration fees regardless of whether the asset belongs to a homeowner, an aggregator, a utility, or an automaker.

The hardware is commodity. The grid services are well understood. What remains unresolved is the business model layer: who enrolls the customer, who dispatches the asset, who captures the margin between a retail incentive payment and wholesale market revenue.

The deadlines. FERC Order 2222, which requires regional transmission operators to allow distributed resource aggregations into wholesale markets, faces compliance deadlines at ISO-NE in November 2026 and NYISO in December 2026. PJM’s timeline remains contested. Each deadline forces a regional answer to the ownership question, because aggregation rules, minimum system sizes, telemetry requirements, and performance obligations will structurally favor one model over another.

New Orleans is building with public settlement funds and third-party orchestration. Illinois is opening wholesale markets to competitive aggregators. Minnesota may hand ownership to the incumbent utility. Rivian is turning its vehicle fleet into the grid asset itself. Each program is advancing on its own timeline, under its own regulatory framework, with its own theory of who should profit from distributed flexibility.

None of them is waiting for the others. The distributed grid is being assembled through settlement agreements in Louisiana, legislative mandates in Illinois, regulatory proceedings in Minnesota, and software integrations across dozens of utility territories. By the time Order 2222 compliance deadlines arrive this fall, the ownership question may already be answered by deployment rather than by design.

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