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A new wholesale energy market policy proposal in New York could undermine market efficiency by limiting the compensation available for energy storage resources. The New York Independent System Operator (NYISO) recently submitted changes to its market rules to encourage energy storage, as required by an order from the Federal Energy Regulatory Commission (Order No. 841). The filing prevents energy storage resources from participating in the wholesale markets if they also participate in retail compensation programs. We submitted comments explaining how this participation barrier is inconsistent with FERC’s requirements and should be changed.