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Conventional measurement and verification for non-interval metered, direct load control (DLC) programs bidding into wholesale electricity markets usually requires a PURPA-compliant load research study. This requirement contributes to high operating costs and has been a factor in recent reductions in the amount of emergency demand response available to regional transmission system operators. This paper describes a collaborative effort by PJM members to determine whether regional modeling using pooled historical data could satisfy DLC measurement and verification (M&V) requirements without sacrificing estimation accuracy. This paper also describes how PJM incorporated the regional "deemed savings estimates" into its Load Data Systems Manual. This paper concludes that regional approaches to M&V could yield large cost savings for DLC resource providers around the country.