On April 10, 2020, the Federal Energy Regulatory Commission (FERC) issued an order (April Order) on PJM Interconnection, LLC’s (PJM) proposal for minimum run-time requirements for capacity storage resources. The April Order relates to Order No. 841 from December 2018, which opened energy markets to energy storage, and a FERC order from October 2019, where PJM obtained FERC’s green light to implement its energy storage proposals in compliance with Order No. 841, but also instituted an investigation under section 206 of the Federal Power Act to examine whether PJM’s proposed minimum run-time requirements for capacity storage resources are unjust, unreasonable, or unduly discriminatory as applied to capacity storage resources. In the same proceeding, FERC directed PJM to submit tariff provisions reflecting its minimum run-time rules applicable to all resources. These developments are covered in the prior GT Alert, “Thumbs Up for Energy Storage: FERC Approves PJM and SPP Proposals Implementing Order No. 841.”