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This paper investigates the possibility of providing aggregated regulation services with small loads, such as water heaters or air conditioners. A direct-load control algorithm is presented to aggregate the water heater load for the purpose of regulation. A dual-element electric water heater model is developed, which accounts for both thermal dynamics and users' water consumption. A realistic regulation signal was used to evaluate the number of water heaters needed and the operational characteristics of a water heater when providing 2-MW regulation service. Modeling results suggest that approximately 33 000 water heaters are needed to provide a 2-MW regulation service 24 hours a day. However, if water heaters only provide regulation from 6:00 to 24:00, approximately 20 000 will be needed. Because the control algorithm has considered the thermal setting of the water heater, customer comfort is maintained. Therefore, the aggregated regulation service provided by water heater loads can become a major source of revenue for load-serving entities when the smart grid enables the direct load control.