The Advanced Power Alliance (APA) and the Southern Renewable Energy Association (SREA) have filed joint comments with the Louisiana Department of Conservation and Energy on its proposed Regulation of Renewable Energy Storage Facilities.
The Legislature gave the Department a clear and limited job in Act 279 of 2025. Louisiana Revised Statute 30:1131 requires a permit before batteries are installed, a decommissioning plan, and proof of financial security. We support responsible decommissioning and real financial protection for landowners. The draft rule reaches well beyond that framework, and the added cost lands on projects, investors, and ultimately Louisiana ratepayers.
Our comments focus on three priorities:
- Define restoration. The rule should set a documented baseline and clear completion standards at plan approval. Operators cannot price or secure an obligation that can grow at the end of a project’s life, and they should not be required to tear out shared roads, wires, or switchyards still serving an operating facility.
- Right-size engineering requirements. Requiring a Louisiana-licensed engineer to prepare and seal the entire plan, including financial and administrative documents, adds cost without adding value. Engineering seals should apply to engineering work.
- Remove compelled operations. The statute provides for installation permits and decommissioning. It does not authorize the Department to order a facility to resume charging or dispatching power.
We also recommended tying the rule’s applicability to the existing 75-acre solar permit threshold, crediting salvage and recycling value and security already posted with landowners and parishes, setting firm review deadlines, and protecting existing facilities that already have adequate decommissioning arrangements in place.
Louisiana has made fast, predictable permitting a priority through the Lightning Speed Initiative. A storage rule that stays within its statutory lane would advance that goal and keep Louisiana competitive for the investment, jobs, and reliable power that battery storage brings.
Our thanks to the Southern Renewable Energy Association and to our members for their work on these comments. The full filing is available here: SREA/APA Comments to Louisiana DCE