The implementation challenge isn't distributed storage technology, it’s the regulatory and operational framework that surrounds it.
Battery energy storage is one of the most talked-about tools in the clean energy transition — and one of the most frustratingly difficult to actually deploy at scale. Today, the Center for Renewables Integration (CRI) and Pure Power Engineering are releasing a new white paper that cuts through the regulatory and operational complexity: Making Distributed Storage Work in Your State.
Written by CRI co-founder Kerinia Cusick, DER interconnection expert Mrinmayee Kale, and energy consultant Rao Konidena, this paper provides guidance for state utility commissions, legislators, energy offices, and consumer advocates.
Why This Paper, Why Now
The timing couldn't be more urgent. In 2026, for the first time in history, PJM ISO was unable to procure adequate supply to meet its reliability needs. Across the country, load projections are spiking as data centers race to connect to the grid, while new generation faces rising costs and supply chain bottlenecks. Battery energy storage systems are uniquely positioned to solve these problems — they deploy quickly, respond to grid conditions nearly instantaneously, and can be sited stand-alone or co-located with load.
Four Barriers — and the Solutions That Are Working
Drawing on direct participation in state commission dockets and federal regulatory proceedings, the authors identify four persistent challenges and the state-level solutions gaining traction:
Including BESS in distribution planning. Most EDC planning processes don't allow BESS, particularly third-party owned, to be included as a peak load reduction resource — meaning ratepayers never see the grid benefit batteries are providing. To do that, EDCs need operational assurance BESS will perform as needed.
Getting the tariffs right. FERC Orders 841 and 2222 have established a wholesale framework, but retail rate structures remain underdeveloped in most states. Rhode Island's effort to build the first comprehensive bi-directional retail tariff for front-of-meter BESS is worth watching.
Ending the "load vs. BESS" competition. In states that haven't updated interconnection rules, batteries and new load can compete for the same substation capacity. The paper argues this is a policy failure — not a physical one. Options need to be provided to study load and generation as one.
Standardizing EDC-BESS communication. The standards already exist — IEEE 1547-2018, UL 1741 SB, and IEEE 2030.5 are built into virtually every commercially available BESS inverter in the U.S. today. State commissions should require EDCs to adopt them rather than mandate proprietary solutions for each EDC that ratepayers end up funding.
A Resource Built From the Field
What distinguishes this white paper is that its authors didn't write it from the sidelines. Cusick has served as an expert witness in energy storage proceedings, advised developers and investors, and contributed to New York's energy storage roadmap. Kale has worked for a decade at the nexus of distribution grid interconnection technical and regulatory compliance across multiple states. Konidena spent 15 years at MISO and regularly provides technical testimony before state and federal energy commissions. The case studies in this paper are drawn from proceedings, some of which the authors participated in directly.
Making Distributed Storage Work in Your State is available now.
For additional questions please contact, Kerinia Cusick at kcusick@center4ri.org.