News & Analysis as of

Cost Allocation Federal Energy Regulatory Commission

Troutman Pepper Locke

Order No. 1920-B Affirms FERC’s Long-Term Transmission Planning and Cost Allocation Rule

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On April 11, 2025, FERC issued Order No. 1920-B, which clarified and maintained key requirements from Order No. 1920-A regarding long-term transmission planning and cost allocation. FERC clarified that transmission providers...more

Troutman Pepper Locke

FERC Accepts SPP’s Tariff Revisions Regarding Distribution of Make-Whole Payments for Self-Committed Resources

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On March 27, 2025, FERC approved Southwest Power Pool, Inc.’s (SPP) tariff revisions to remove the opportunity for resources that self-commit during the Reliability Unit Commitment Process (RUC) to avoid contributing to RUC...more

Holland & Knight LLP

FERC Takes Action on Co-Located Load in PJM

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The Federal Energy Regulatory Commission (FERC or Commission) on Feb. 20, 2025, initiated a review of issues associated with the co-location of large loads (such as data centers) at generating facilities in the PJM...more

Troutman Pepper Locke

FERC Institutes Show Cause Proceeding on Co-Location Issues in PJM

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On February 20, 2025, FERC found that the PJM Interconnection, L.L.C. (“PJM”) Open Access Transmission Tariff (“OATT”) appears to be unjust and unreasonable because it does not address with clarity or consistency the rates,...more

Paul Hastings LLP

FERC Issues Landmark Transmission Planning Order

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On May 13, 2024, the Federal Energy Regulatory Commission (FERC) issued Order No. 1920, its long‑awaited transmission planning and cost allocation final rule (Transmission Order) regarding proposed reforms to the regional...more

Troutman Pepper Locke

High-Level Summary of FERC Order No. 1920 on Transmission Planning and Cost Allocation

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On May 13, the Federal Energy Regulatory Commission (FERC or Commission) released its Order No. 1920 (Final Rule) to reform its policies regarding Regional Transmission Planning and Cost Allocation.1 The Final Rule follows...more

Vinson & Elkins LLP

FERC Issues Final Rules on Electric Transmission Planning, Cost Allocation, and Backstop Authority Evaluation Procedures

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On May 13, 2024, the Federal Energy Regulatory Commission (“FERC” or “Commission”) established “a new foundation” upon which new electric transmission facilities can be planned, paid for, and built. The Commission did so...more

Perkins Coie

FERC Issues Historic Rules on Regional Transmission Planning, Cost Allocation, and Siting

Perkins Coie on

At a special meeting on May 13, 2024, the Federal Energy Regulatory Commission (FERC) issued two eagerly awaited final rules regarding transmission reform. The first rule, Order No. 1920, mandates changes to the regional and...more

Jenner & Block

Client Alert: FERC Issues Final Rule on How to Plan and Pay for Electricity Transmission

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On May 13, 2024, the Federal Energy Regulatory Commission (FERC) issued its long-awaited final rule on regional transmission planning and cost allocation, Order No. 1920. The final rule’s release follows a notice-and-comment...more

Troutman Pepper Locke

FERC Reverses Course, Rejects SPP Byway Cost Allocation Proposal for Second Time

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On July 13, 2023, FERC on rehearing set aside its prior order that had accepted Southwest Power Pool, Inc.’s (“SPP”) proposal to establish a case-by-case process to allocate, on a regional, postage-stamp basis, all of the...more

Troutman Pepper Locke

D.C. Circuit Backs FERC in New York Cost Allocation Dispute, Giving FERC Broad Deference under the Rule of Reason

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On July 7, 2023, the U.S. Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) issued an opinion rejecting petitioner Hecate Energy Green County 3 LLC’s (“Hecate”) claim that the New York Independent System...more

Bracewell LLP

FERC Issues Proposal To Overhaul Transmission Planning and Cost Allocation

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On April 21, 2022, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a much-anticipated Notice of Proposed Rulemaking (“NOPR”) proposing changes to its transmission planning and cost allocation policies...more

Vinson & Elkins LLP

FERC Proposes Major Reforms and Commences a Multi-Pronged Approach to Tackle Transmission Planning and Cost Allocation

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On April 21, 2022, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a Notice of Proposed Rulemaking (“NOPR”) aimed at reforming long-term regional transmission planning. ...more

Husch Blackwell LLP

FERC’S Next Big Electric Initiative

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On April 21, 2022 a split Federal Energy Regulatory Commission (“FERC”) approved 4-1 a Notice of Proposed Rulemaking (“NOPR”) on transmission planning and cost allocation. Issued pursuant to section 206 of the Federal Power...more

Husch Blackwell LLP

Updates on FERC Transmission Planning Process Reform

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Regulatory Update – FERC transmission planning process reform- On July 15, 2021, the Federal Energy Regulatory Commission (“FERC”) issued an Advanced Notice of Proposed Rulemaking (“ANOPR”) to broadly examine FERC’s...more

Perkins Coie

FERC Steps Toward Potential Overhaul of Transmission Planning and Cost Allocation

Perkins Coie on

The Federal Energy Regulatory Commission recently signaled potential wide-reaching reforms to regional electric transmission planning, cost allocation, and generator interconnection processes. Nearing the tenth anniversary of...more

K&L Gates LLP

FERC Issues Advance Notice of Proposed Rulemaking to Reform Transmission Planning, Cost Allocation, and Generator Interconnection...

K&L Gates LLP on

On 15 July 2021, the Federal Energy Regulatory Commission (FERC) issued an Advanced Notice of Proposed Rulemaking (ANOPR) to investigate whether reforms are needed to improve regional transmission planning, cost allocation,...more

Morgan Lewis

DC Circuit Affirms FERC Decision on MISO Cost Allocation

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The US Court of Appeals for the District of Columbia denied challenges to Federal Energy Regulatory Commission orders that rejected a Midcontinent Independent System Operator (MISO) cost allocation proposal on the grounds...more

Akin Gump Strauss Hauer & Feld LLP

Carbon Pricing Update: Assessing NYISO’s Carbon Pricing Straw Proposal

The New York Independent System Operator (NYISO) recently released a Carbon Pricing Straw Proposal (Proposal) to advance the State’s energy and environmental goals by reflecting the cost of carbon emissions in wholesale...more

Akin Gump Strauss Hauer & Feld LLP

D.C. Circuit Upholds Order No. 1000, FERC’s Landmark Transmission Planning and Cost Allocation Rulemaking Order

On August 15, 2014, the United States Court of Appeals for the District of Columbia Circuit unanimously affirmed Order No. 1000, a landmark set of rules approved by the Federal Energy Regulatory Commission (FERC) in 2011 to...more

Akin Gump Strauss Hauer & Feld LLP

Déjà Vu, All Over Again: Seventh Circuit Again Remands PJM’s Cost Allocation Methodology for New, High-Voltage Transmission...

On June 25, 2014, the U.S. Court of Appeals for the Seventh Circuit, with Judge Richard A. Posner writing for himself and Judge John Daniel Tinder, granted petitions for review of Federal Energy Regulatory Commission (FERC)...more

Akin Gump Strauss Hauer & Feld LLP

Appellate Court Upholds FERC Decisions on CAISO Must-Offer Cost Allocation

The U.S. Court of Appeals for the District of Columbia Circuit this week upheld two Federal Energy Regulatory Commission (FERC) orders allocating the costs associated with mitigating transmission constraints on a Southern...more

Stinson LLP

Energy Insight: Order No. 1000 Update—FERC’s Initial Compliance Orders

Stinson LLP on

The utility and transmission industry received significant guidance today from the Federal Energy Regulatory Commission on the direction FERC intends to take in its implementation of Order No. 1000. Order No. 1000...more

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