Energy developers evaluating Wisconsin for energy storage projects now have something the Wisconsin market has largely lacked: a clearer path for energy storage projects to apply to the Public Service Commission for a Certificate of Public Convenience and Necessity (CPCN) both as standalone projects or when paired with generation.

In April 2026, the Public Service Commission of Wisconsin (PSC) published dedicated Application Filing Requirements (AFRs) for energy storage systems. The new energy storage AFRs provide developers with a more defined framework for what the Commission will expect when reviewing energy storage systems and technologies, particular standalone energy storage projects. The AFRs request information similar to other energy generation AFRs such as project engineering and technical details, site selection, interconnection status, environmental impacts, decommissioning, local outreach and DNR coordination. However, the new storage AFRs also request storage-specific detail that has not been central to prior applications involving storage to this point, including emergency response planning, fire suppression, hazardous materials, PFAS and coordination with local fire and municipal officials. 

Prior to the release of the storage AFRs, review of energy storage in Wisconsin has occurred mostly through projects where battery energy storage systems (BESS) were paired with energy generation, particularly solar. Although a small number of storage-only proposals have been submitted, none have been deemed complete nor advanced far enough in the PSC process to create a practical permitting roadmap. The new storage AFRs appear aimed at providing that roadmap and indicate the PSC’s readiness to review standalone energy projects.

The new AFRs apply to both standalone energy storage projects and projects that combine storage with energy generation. For energy storage that is part of a larger generation project, the PSC recommends combining the energy storage application materials into the relevant sections of the generation facility application but the AFRs do not describe how exactly that incorporation should occur.

Wisconsin remains a promising market for energy storage as utilities, data centers, large energy customers, and renewable energy developers seek capacity, resiliency and grid flexibility all with speed to market at the forefront. However, energy storage projects will require Wisconsin-specific regulatory planning from the outset to ensure projects move forward as efficiently as possible.

Local counsel familiar with the PSC and permitting process can help developers build a strong application and move toward successful permitting without avoidable delay. The experienced Energy team at Godfrey & Kahn is uniquely well positioned to guide energy storage developers through this permitting process, with deep Wisconsin energy regulatory experience, strong relationships with regulators and the PSC, and a practical understanding of how state permitting, local siting, utility procurement and project development issues intersect in Wisconsin.