CAISO’s Market Monitor is concerned about potential gaming and inefficient bidding behavior in CAISO’s bid cost recovery (BCR) process for battery storage resources.
The current BCR design creates gaming opportunities for battery storage units, “especially through manipulation of various biddable parameters used to manage [a battery’s] state-of-charge,” CAISO’s Department of Market Monitoring (DMM) said in its annual market performance report, published Aug. 7.
“Gaming concerns are exacerbated by the fact that bid cost recovery payments are partly driven by submitted bid prices, meaning that inflated bids can cause BCR payments to drastically exceed any economic losses caused by reversal of day-ahead schedules,” DMM said in the report.
Battery storage capacity in California has grown from 500 MW in 2020 to almost 14,000 MW as of August. An additional 14,000 MW of battery storage capacity is planned to be online by 2030, pushing CAISO’s total to about 28,000 MW by that year.
In 2024, battery storage facilities received about $18 million in real-time bid cost recovery — about 11% of all bid cost recovery in the year. However, battery storage resources are different from conventional resources: They do not have start-up, shut-down, minimum load or transition costs — the primary drivers of BCR, the report says.
Historically, BCR has applied to generation facilities as a method to reduce their risk of receiving insufficient revenue to cover start-up and minimum load costs, the report says. As opposed to conventional thermal resources that are incentivized to bid their marginal energy production costs, storage resource bids do not solely represent the costs to discharge or charge energy in a given interval, CAISO said in a November 2024 letter to FERC on the issue.
“As a result, bid cost recovery payments to storage resources may result in compensation exceeding the resource’s costs,” CAISO said in the letter.
In its Aug. 7 report, DMM recommended that battery storage resources should be, in general, ineligible for BCR, with a limited number of conditions in which they would be eligible for BCR. The report notes that batteries do have certain limits that can result in BCR payments, specifically state-of-charge constraints that limit a battery storage unit’s charging and discharging behavior.
But, as a general principle, when batteries are constrained by operational parameters set by unit operators to manage battery operation, “batteries should be ineligible for BCR payments,” the DMM’s report says.
Additional Revisions
In November 2024, CAISO filed a tariff amendment to address the battery storage BCR gaming concern. The tariff amendment caps battery bids when calculating bid cost recovery payments, which will mostly address the ability of batteries to inflate unwarranted BCR payments, DMM’s report says.
However, unwarranted BCR payments will continue after the policy change is implemented because batteries with day-ahead schedules will continue to have distorted bidding incentives in real time, DMM’s report says. This is because the largest driver of real-time battery BCR is due to lost revenues of buying or selling back day-ahead schedules, the report says.
The current BCR design “essentially removes the economic incentive for battery operators to bid in a way that is likely to ensure that batteries are fully charged up at the start of the peak net load hours when prices are highest and batteries are most needed for system reliability,” the report says.
Responding to questions from RTO Insider, a CAISO spokesperson said the ISO and stakeholders developed market design changes in 2024 to eliminate the potential for strategic bidding that would unduly inflate battery BCR payments. While those changes addressed an important concern, CAISO is working through additional issues related to market efficiency and improving the incentives for batteries to bid in a manner that is cognizant of real-time prices, the spokesperson said. BCR payments to batteries have remained stable even with significant battery fleet growth, they said.
CAISO is working on additional revisions to the BCR process within the agency’s storage design and modeling initiative that started in 2025.

