Policy Work
California’s Most Effective Advocate for Energy Storage
We show up everywhere it matters—CPUC, CAISO, the Legislature, and beyond.
CESA is California’s most active and effective advocate for the storage industry—and we show up everywhere it matters, at the federal, state, and local levels. At the CPUC. At CAISO. At the California Legislature. At the CEC. At FERC. At local jurisdictions trying to block your projects.
We are there. We provide expertise. And we deliver.
California has the most complex energy policy landscape in the nation, and CESA’s job is to cut through it on behalf of our members. We turn that complexity into opportunity—growing the market, shaping the rules, and ensuring storage gets the recognition, procurement, and market access it deserves.
Here’s what that looks like in practice:
- We grow the market — securing landmark procurement orders and pushing California toward a future where storage is central to grid reliability.
- We fix the rules — clearing away regulatory barriers, artificial constraints, and local restrictions that stand between your projects and the finish line.
- We shape market design — ensuring storage is properly modeled, priced, and dispatched so our members can compete and win.
We do this grounded in three core principles: we champion all forms of storage; we fight for competitive and transparent markets; and we engage collaboratively and constructively—because lasting wins require building coalitions, not just filing comments.
Explore below to see our key accomplishments and the work we’re doing right now to keep storage moving forward in California.
Key CESA Victories!
CESA supported the passage of SB 302 that excludes IRA-related clean energy tax credits from CA taxable income.
CESA shaped AB 205 Budget Act to secure $140M for the CEC’s Long Duration Energy Storage Program.
CESA supported and shaped passage of SB 1369, which defines green electrolytic hydrogen and directs CA agencies to include green electrolytic hydrogen as a form of energy storage.
CESA sponsored and passed AB 546 to require the CEC to develop an energy storage permitting guidebook.
CESA shaped passage of AB 2861 to establish an interconnection dispute resolution process.
CAISO updates market rules to no longer prevent energy storage from submitting day ahead market bids up to the soft offer cap of $2K.
CAISO adopted various interconnection process enhancements, including deliverability allocation groups.
FERC approved WDAT storage distribution service rates via settlement.
CPUC refined the Emergency Load Reduction Program to compensate exports from behind-the-meter resources.
CPUC adopted energy storage eligibility to ReMAT and PURPA projects.
CPUC approved V2X interconnection rules.
CAISO adopted guardrails to use of minimum state of charge (MSOC) requirement for energy storage resources.
CPUC adopted an IRP for 2,200 MW of energy storage to meet the 42 MMT GHG target by 2030.
CPUC approved 567.5 MW in PG&E Moorpark Calpine Reliability Must Run procurement.
CPUC ordered 104.5 MW of energy storage procurement in response to the Aliso Canyon emergency.
CPUC approved major SGIP reforms prioritizing BTM storage and supporting LDES.
CPUC orders 261 MW in historic SCE LCR procurement.
CPUC adopts 1,325 GW energy storage procurement mandate.
Policy and Regulatory Activity Shaped by Our Member Working Groups
Each Working Group channels member feedback into focused regulatory engagement, ensuring California's clean energy transition is supported by practical, market-driven policy solutions.
The Safety and Permitting Working Group convenes CESA members and stakeholders to advance best practices for energy storage safety, system design and siting and permitting. The group tracks updates to fire codes, safety standards, and research developments, while coordinating industry input into regulatory and code-development processes. Its work helps ensure safe deployment of storage technologies while supporting continued market growth. The group also tracks and engages in land use and permitting topics related to storage, including local ordinance development and zoning code updates.
The California Independent System Operator (CAISO) Working Group engages in wholesale market design and operational rules that shape how energy storage participates in California and across the West’s grid. Members collaborate to improve market modeling of storage operations, ensure markets reflect real-time opportunity costs energy storage resources face, and address issues such as uplift payments, hybrid participation, and state-of-charge management. These efforts help ensure storage resources are efficiently dispatched and fairly compensated in CAISO markets.
- November 26, 2025 - Storage Design and Modeling Comments
CESA urges CAISO to implement a Fall 2026 market modeling solution that enables BAA-level market power mitigation (MPM) and scarcity pricing.
- November 13, 2025 - 2026-2029 Draft Roadmap
CESA supports CAISO’s effort to establish a foundational and actionable roadmap that helps guide stakeholder engagement on market design and operational priorities.
- October 13, 2025 - Storage Design and Modeling Comments - Working Group
CESA urges CAISO to implement outage management reforms that appropriately account for storage state-of-charge and operations while maintaining reliability needs.
- September 22, 2025 - Congestion Revenue Rights Enhancements WG 7
CESA urges CAISO to coordinate the Congestion Revenue Rights Enhancements initiative with the broader Transmission Access Charge (TAC) rewrite to ensure alignment and avoid conflicting market design outcomes.
- September 19, 2025 - Price Formation Enhancements: BAA-Level MPM and Scarcity Pricing
CESA urges CAISO to implement BAA-level market power mitigation and scarcity pricing to improve market efficiency and reliability and to support resource adequacy procurement.
- September 5, 2025 - Storage Design and Modeling Comments - Working Group
CESA urges CAISO to implement outage management reforms that appropriately account for storage state-of-charge and operations while maintaining reliability needs.
- August 12, 2025 - Storage Design and Modeling - CESA Presentation
CESA urges CAISO to adopt a BAA-level grouping approach for storage market power mitigation and scarcity pricing to better reflect how storage resources operate in real time.
- July 16, 2025 - Storage Design and Modeling Comments
- June 11, 2025 - Storage Design and Modeling Comments
- May 23, 2025 - Storage Design and Modeling - Outage
CESA supports CAISO’s proposed outage management enhancements for storage resources, emphasizing the importance of accurately accounting for state-of-charge and operational constraints.
- May 13, 2025 - Storage Design and Modeling - Flexible Ramping Product SOC BMP Changes
The Resource Adequacy (RA) Working Group focuses on California’s capacity planning framework and policies that determine how storage resources contribute to grid reliability. Members engage on reforms to capacity accreditation, resource availability rules, and procurement structures at both CAISO and CPUC. Key topics include hybrid capacity methodologies, hourly capacity frameworks, and long-duration storage accreditation, all of which directly influence the value and role of storage in meeting reliability requirements.
- November 18, 2025 - Informal Comments on the RA Workshop
CESA provided informal comments highlighting the need for resource adequacy reforms that better accommodate storage and support a reliable, least-cost portfolio.
- November 14, 2025 - OIR Reply Comments
CESA submitted reply comments supporting reforms to California’s resource adequacy program that improve alignment with actual system needs and storage capabilities.
- September 24, 2025 - CAISO RAMPD Initiative: Comments on Track 1 DFP Revision
CESA submitted comments on CAISO’s RAMPD Track 1 revision, supporting changes that improve the treatment and valuation of storage within the resource adequacy construct.
- September 19, 2025 - CAISO RAMPD Initiative: Comments on Track 2 Straw Proposal
CESA submitted comments on CAISO’s RAMPD Track 2 straw proposal, urging design improvements to better recognize storage operational attributes and system value.
- September 12, 2025 - CAISO RAMPD Initiative: Comments on Track 1 Draft Final Proposal
CESA submitted comments on CAISO’s Draft Final Proposal for RAMPD Track 1, encouraging changes that improve storage participation and reliability outcomes.
- August 12, 2025 - CAISO PRR 1634 Response To Reply: Plant Trouble Outage Card Definition
CESA submitted response-to-reply comments on PRR 1634, emphasizing clarity and appropriate definitions for outage reporting that do not unintentionally disadvantage storage resources.
- July 16, 2025 - CAISO PRR 1634: Plant Trouble Outage Card Definition
CESA submitted comments on PRR 1634 urging CAISO to ensure outage card definitions and implementation details appropriately reflect storage operating characteristics.
- June 25, 2025 - CAISO RAMPD Initiative: Comments on Track 1 Straw Proposal
CESA submitted comments on CAISO’s RAMPD Track 1 straw proposal, supporting reforms that improve the integration and valuation of storage in planning and procurement.
- March 17, 2025 - R2310011 Track 3 Reply Comments
CESA filed reply comments in the CPUC’s resource adequacy proceeding, supporting policy changes that improve reliability while better accommodating storage resources.
The Integrated Resource Plans (IRP) Working Group engages in California’s long-term planning process to ensure energy storage capabilities are accurately reflected in system modeling and procurement decisions. Members review modeling assumptions, resource valuation methods, and planning scenarios that determine least-cost portfolios for meeting reliability, emissions, and clean energy goals. This work helps ensure that storage resources are appropriately considered and valued in future grid planning and procurement strategies.
- October 31, 2025 - R.25-06-019 Reply Comments on TPP / Additional Procurement
CESA submitted reply comments supporting additional procurement and planning approaches that better recognize storage value and support grid reliability.
- October 22, 2025 - R.25-06-019 Opening Comments on TPP / Additional Procurement
CESA submitted opening comments supporting a balanced procurement approach and planning framework that enables cost-effective deployment of long-duration storage.
- August 5, 2025 - R.20-05-003 RCPPP Reply Comments
CESA submitted reply comments supporting procurement pathways that facilitate timely storage deployment and improved system reliability.
- August 5, 2025 - R.20-05-003 Response to ACP-CA Motion for Expedited Procurement
CESA filed a response addressing expedited procurement considerations and underscoring the role storage can play in meeting near-term reliability needs.
- July 15, 2025 - R.20-05-003 RCPPP Comments
CESA submitted comments on the Resource Capacity Procurement Planning Process supporting procurement structures that better enable storage to serve reliability needs.
The Emerging Technologies & Long-Duration Storage Working Group explores policy pathways and market opportunities for next-generation energy storage technologies, including long-duration energy storage (LDES). The group evaluates procurement frameworks, funding opportunities, and regulatory developments that can accelerate commercialization and grid integration of emerging storage technologies. Note: This working group is currently merged with the IRP working group.
The Distributed Energy Resources (DER) Working Group advocates for policies and programs that expand deployment and compensation opportunities for distribution-connected storage, spanning both front-of-meter and behind-the-meter systems. The group works to improve interconnection processes and strengthen demand response frameworks. It also pursues funding for distributed energy programs and works to reduce unnecessary regulatory burdens on distributed storage resources.
- November 13, 2025 - R.25-09-004 Opening Comments on CPUC's OIR to Enhance Demand Response
CESA submitted opening comments supporting demand response enhancements that improve integration with storage and support a more flexible, reliable grid.
- October 20, 2025 - R.25-08-004 Comments on CPUC's OIR to Update Distribution Level
- August 18, 2025 - Answer filed in support of SDCP/CEA's Motion regarding CAISO’s proposed tariff revisions including problematic removal of the Independet Study Process
- July 3, 2025 - Response to CALSSA's PFM to REMOVE NEM/NBTStorage Sizing Limit
CESA filed a response supporting removal of the NEM/NBT storage sizing limit to enable better customer economics and grid benefits from paired storage.
- May 8, 2025 - Response to PFM on SGIP Requirements
CESA filed a response regarding SGIP requirements, supporting updates that better align program rules with modern storage capabilities and market conditions.
- April 25, 2025 - Comments on CAISO's DDEMI Initiative
CESA submitted comments on CAISO’s DDEMI initiative supporting improvements that enable distributed resources and storage to participate effectively and reliably.
- March 28, 2025 - DDEMI Comments
CESA submitted DDEMI comments supporting market rule changes that facilitate DER aggregation and improve storage participation.
The Legislation Working Group (Board Members Only) enables CESA Board Members to guide the organization’s legislative strategy and policy priorities. Working with CESA staff and Sacramento lobbyists, the group evaluates proposed legislation, develops advocacy strategies, and educates policymakers about the value of energy storage in supporting California’s reliability and clean energy goals.