Policy Work
CESA has made grid-connected storage a leading focus area for California and beyond. California policymakers now understand the tremendous role energy storage can play to optimize the electric power system.
CESA Delivers Top-Tier Stakeholder Engagement
To execute our mission, CESA ensures that member interests are represented
and appropriately considered in the key forums shaping California’s electric grid:
Key CESA Victories!
Legislative Wins
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.
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 CEC LDES Program.
CESA shaped AB 205 Budget Act to secure $140M for CEC LDES Program.
2018
SB 700 & SB 1369
CESA supported and shaped passage of SB 700 that extended 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.
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 as reliability solution in response to Aliso Canyon emergency.
CESA sponsored and passed AB 546 to get CEC to develop energy storage permitting guidebook.
CESA sponsored and passed AB 546 to get CEC to develop 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.
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 successful advocates for inclusion of 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 – created energy storage rulemaking and required CPUC to set a procurement target.
Regulatory Wins
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.
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.
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 incremental exports.
FERC approved WDAT storage distribution service rates via settlement.
CPUC refined the Emergency Load Reduction Program to compensate incremental exports.
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.
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.
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.
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.
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.
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.
CPUC orders 261 MW in historic SCE LCR procurement.
CPUC adopts 1,325 GW energy storage procurement mandate.
2011
Storage Rulemaking Implemented
CPUC implements the bill via Storage Rulemaking.
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.
Each Working Group channels member feedback into focused regulatory engagement, ensuring California’s clean energy transition is supported by practical, market-driven policy solutions.
California Independent System Operator (CAISO)
The CAISO Working Group focuses on wholesale market design, market products, and planning processes, including the establishment of hybrid market participation and the representation of storage marginal costs within 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
Distributed Energy Resources (DER)
The DER Working Group focuses on programs and policies that impact distribution-level front-of-meter and behind-the-meter resources, including the Self-Generation Incentive Program, demand response and interconnection.
- 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.
Emerging Technologies & Long-Duration Storage
The Emerging Technologies and Long Duration Working Group develops market pathways and funding opportunities for emerging technologies, including long duration energy storage.
Integrated Resource Plans (IRP)
The IRP Working Group focuses on IRP modeling, policies, and storage procurement, as well as long duration energy storage procurement, and more.
- 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.
Resource Adequacy (RA)
The RA Working Group focuses on California’s RA policy framework and capacity planning tools, such as implementation of the Central Buyer Entity (CBE), improvements to hybrid capacity methodologies, and reforms related to energy and hourly capacity.
- 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.
Safety, Codes, & Standards
The Safety Working Group convenes CESA members and energy storage system stakeholders to collaborate on safety best practices, including updates on codes and standards, research, and safety policy.
Legislation (Board Members Only)
Through the Legislative Working Group, CESA Board Members work with CESA staff and our Sacramento lobbyists to advance storage through legislative action, and educate key decision-makers about the value of energy storage.