While PJM’s Electric Storage Resource (ESR) model went into production in 2019 in compliance with FERC Order 841, the current model may not lead to the most optimal use of this limited-duration resource. PJM has a compliance requirement with FERC to update the model in 2026 to “account for state-of-charge.” While updating the model to “account for state-of-charge” will address infeasible dispatch, it will still fall short of recognizing the opportunity cost associated with the limited duration and energy storage resources. With storage integration expected to increase in PJM’s footprint, there is an opportunity to revisit how PJM accounts for state-of-charge and more broadly review the existing ESR model and business rule design with a view toward allowing storage to effectively participate in PJM’s market at higher penetration levels.