---
title: Policy Work (Draft Updates)
description: CESA advances energy storage policy in California, promoting market growth and stakeholder engagement while ensuring safe, reliable pathways for a clean energy transition.
---

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# 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.

- ![California-Public-Utilities-Commission-1](https://storagealliance.org/hs-fs/hubfs/California-Public-Utilities-Commission-1.jpg?width=250&height=250&name=California-Public-Utilities-Commission-1.jpg)
- ![California-Independent-System-Operator-1](https://storagealliance.org/hs-fs/hubfs/California-Independent-System-Operator-1.jpg?width=250&height=250&name=California-Independent-System-Operator-1.jpg)
- ![California-Legislature-1](https://storagealliance.org/hs-fs/hubfs/California-Legislature-1.jpg?width=250&height=250&name=California-Legislature-1.jpg)
- ![California-Energy-Commission](https://storagealliance.org/hs-fs/hubfs/California-Energy-Commission.jpg?width=250&height=250&name=California-Energy-Commission.jpg)
- ![Federal-Energy-Regulatory-Commission-1](https://storagealliance.org/hs-fs/hubfs/Federal-Energy-Regulatory-Commission-1.jpg?width=250&height=250&name=Federal-Energy-Regulatory-Commission-1.jpg)

## 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!

Legislative Wins

2026

SB 1183

As part of a coalition of stakeholders, CESA helped oppose and defeat **SB 1183**.

2025

AB 283 & SB 302

CESA shaped and supported the passage of **AB 283** that strengthens BESS safety.

CESA supported the passage of **SB 302** that excludes IRA-related clean energy tax credits from CA taxable income.

2022

AB 2625 & AB 205

CESA sponsored and passed **AB 2625** to get standalone storage exemptions from the Subdivision Map Act​.

CESA shaped **AB 205** Budget Act to secure $140M for the CEC’s Long Duration Energy Storage Program.

2018

SB 700 & SB 1369

CESA supported and shaped passage of **SB 700** that extended the Self-Generation Incentive Program (SGIP) through 2024.

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.

2017

SB 801 & AB 546

CESA shaped passage of **SB 801** to have energy storage count as a reliability solution in response to the Aliso Canyon emergency.

CESA sponsored and passed **AB 546** to require the CEC to develop an energy storage permitting guidebook.

2016

AB 2868 & AB 2861

CESA shaped **AB 2868** investments and programs for distribution-connected storage.

CESA shaped passage of **AB 2861** to establish an interconnection dispute resolution process.

2015

AB 33

CESA supports passage of **AB 33**, directing CEC and CPUC to analyze the role of LDES.

2014

SB 861

CESA successfully advocated for inclusion of a key provision in **SB 861** to extend the SGIP program to 2019, and expands programs to include distributed energy resources (not just generation technologies).​

2010

AB 2514

CESA worked closely with Governor Jerry Brown to enact **AB 2514**, the world’s first bill focused on energy storage. The bill required the CPUC to open an energy storage proceeding and consider energy storage procurement targets for the state’s utilities.

Regulatory Wins

2026

Battery Foldback Modeling

**CAISO** committed to integrating battery foldback modeling into its market optimization framework by 2027, improving reliability modeling and reducing unnecessary penalties for energy storage resources.

2026

CPUC Approves 6 GW Procurement Order

CESA successfully advocated for removal of a proposed 50 percent cap on energy storage procurement, preserving flexibility for load-serving entities and supporting greater storage deployment.

2025

Balanced Permitting

CESA shaped balanced permitting guidelines with state and local agencies and helped avert local moratoria on **BESS** projects.

2024

Storage Procurement Secured

**CPUC** establishes the need for centralized procurement of 1 GW of 12+ hour emerging storage and ​1 GW of multi-day storage.

**CAISO** updates market rules​ to no longer prevent energy storage from submitting day ahead market bids up to the soft offer cap of $2K.

2022

Storage Market Enhancements

**CAISO** adopted energy storage enhancements to co-located resource functionality and ancillary service proposals​.

**CAISO** adopted various interconnection process enhancements, including deliverability allocation groups.

2021

Storage Policy Wins

**CPUC** adopted additive QC for hybrid and co-located resources.

**FERC** approved WDAT storage distribution service rates via settlement.

**CPUC** refined the Emergency Load Reduction Program to compensate exports from behind-the-meter resources.

2021

Storage Policy Wins

**CPUC** issued MTR Procurement Order for 11,500 MW of incremental capacity, including 1,000 MW of LDES by 2026​.

**CPUC** adopted energy storage eligibility to ReMAT and PURPA projects​.

2020

Equity Storage Advanced

**CPUC** approved CESA’s Petition to transfer $108M in SGIP funds to support shovel-ready Equity storage projects​.

**CPUC** approved V2X interconnection rules​.

2020

Storage Rules Refined

**CPUC** directed modifications to LTES dynamic valuation rules in SGIP​​.

**CAISO** adopted guardrails to use of minimum state of charge (MSOC) requirement for energy storage resources​.

2018

Storage Procurement Expanded

**CPUC** adopted a multiple-use applications framework for energy storage.

**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.​

2017

Station Power Rules

**CPUC** adopted station power rules for standalone energy storage systems​.

2016

BTM Storage Expanded

**CAISO** approved MGO performance evaluation for BTM storage under PDR and DERP models.

**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.

2014

First Storage RFO

**CPUC** orders first biennial energy storage RFO procurements​.

2013

Storage Procurement Mandated

**CPUC** orders minimum 50 MW in SCE LTPP plan​​.​

**CPUC** orders 261 MW in historic SCE LCR procurement​.​

**CPUC** adopts 1,325 GW energy storage procurement mandate​.

2011

Storage Rulemaking Implemented

**CPUC** implements AB 2514 (see Legislative Wins above) by opening a rulemaking on energy storage.

2009

SGIP Includes Storage

**CPUC** adds energy storage to SGIP​.

## Policy and Regulatory Activity Shaped by Our Member Working Groups

CESA actively engages in California's major regulatory forums to advance safe, reliable, and market-enabling pathways for energy storage. Our filings are organized by Working Group, reflecting CESA's core areas of regulatory advocacy. To explore recent filings, select a Working Group below to expand the section and view detailed updates.

Each Working Group channels member feedback into focused regulatory engagement, ensuring California's clean energy transition is supported by practical, market-driven policy solutions.

[Contact Us to Learn More!](mailto:awhitt@storagealliance.org)

Safety & Permitting

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. 

California Independent System Operator (CAISO)

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](https://stakeholdercenter.caiso.com/Comments/AllComments/7ebde4c4-2e11-413b-a307-d130a5313c5c)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/efa23f79-fc99-4e24-ac86-eded29e74d06)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/c9903a4c-a900-47d2-b362-51c768a52e73)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/7daa6493-7f77-4f4c-9fb0-5ddcd02334be)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/e56eba92-28eb-4fe6-9f75-b160eae155b8)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/a35d7182-e62e-4559-93c0-80ede736ceba)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/a35d7182-e62e-4559-93c0-80ede736ceba)
  
  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](https://stakeholdercenter.caiso.com/Comments/MyComments/9167b4eb-0cc2-4eef-ae2c-9de975861f85)
- June 11, 2025 - [Storage Design and Modeling Comments](https://stakeholdercenter.caiso.com/Comments/MyComments/358973f2-427a-49c1-9c19-389ad14e4f47)
- May 23, 2025 - [Storage Design and Modeling - Outage](https://stakeholdercenter.caiso.com/Comments/AllComments/a27805...e8-bfd5-abdc49e61dad#org-fa3a41e0-6669-4d1e-9f53-33112471424e)
  
  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](https://stakeholdercenter.caiso.com/Comments/MyComments/358973f2-427a-49c1-9c19-389ad14e4f47)

Resource Adequacy (RA)

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](https://smithmooreassoc.sharepoint.com/:b:/s/CESA/EY9waLGM1ixAn74I_eXJPjMB3kb_y34CAutg2LQ5jCNItQ?e=Amisls)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M587/K122/587122386.PDF)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/4f0b...89-8925-76626f9af90f#org-612946fa-76ee-4f5d-8bb0-f65914cc7452)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/6bed...23-ab09-4e2efb4c108e#org-cb864d5d-793e-4488-9f99-1b9da0f1b362)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/3121...70-8552-fb53693ef1dd#org-1f76eed9-aefa-40ef-894a-2bcf0c019fc4)
  
  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](https://bpmcm.caiso.com/Lists/PRR%20Comments/Attachments/2347/20250812%20CESA%20PRR1634%20Comments%20v1.pdf)
  
  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](https://bpmcm.caiso.com/Lists/PRR%20Comments/Attachments/2342/2025-07-15-CESA-PRR1634-Comments%20v2%20(final).pdf)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/a94d...77-9b5f-11f61d394ccd#org-5c72bb7b-6274-4e1e-ba9a-af820a092681)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M559/K071/559071743.PDF)
  
  CESA filed reply comments in the CPUC’s resource adequacy proceeding, supporting policy changes that improve reliability while better accommodating storage resources.

Integrated Resource Plans (IRP)

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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M585/K815/585815594.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M584/K699/584699855.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M575/K538/575538068.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M575/K059/575059299.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M573/K391/573391861.PDF)
  
  CESA submitted comments on the Resource Capacity Procurement Planning Process supporting procurement structures that better enable storage to serve reliability needs.

Emerging Technologies & Long-Duration Storage

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.*

Distributed Energy Resources (DER)

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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M587/K016/587016005.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M583/K959/583959140.PDF)
- 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](https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20250818-5103)
- July 3, 2025 - [Response to CALSSA's PFM to REMOVE NEM/NBTStorage Sizing Limit](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M572/K574/572574843.PDF)
  
  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](https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M566/K243/566243356.PDF)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/8f7ed6c...4368-a40e-6c96ccd17feb#org-10313e3d-77c8-4384-8374-a887b9ba0a68)
  
  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](https://stakeholdercenter.caiso.com/Comments/AllComments/07dbeae...4b78-9c30-21669fda6eac#org-f2b314d3-9f5e-4cf1-8b01-fdf016557a32)
  
  CESA submitted DDEMI comments supporting market rule changes that facilitate DER aggregation and improve storage participation.

Legislation (Board Members Only)

 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.

## Advocacy That Yields Results

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