News & Analysis as of

Federal Energy Regulatory Commission ISOs

Orrick, Herrington & Sutcliffe LLP

NYISO and ISO-NE Prepare for Potential Import Tariffs on Electric Energy

On February 28, 2025, the New York Independent System Operator, Inc. (NYISO) and ISO New England, Inc. (ISO-NE) submitted proposed revisions to their respective wholesale market tariffs to the Federal Energy Regulatory...more

Morgan Lewis

How Recent FERC Orders Are Regulating Electric Storage, QFs, and Inverter-Based Resources in 2025

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Regulatory developments include FERC’s actions on electric storage resources participating in the wholesale markets, co-location of large electric loads, qualifying facility eligibility, and reliability rules for...more

Troutman Pepper Locke

FERC Announces Commissioner-led Technical Conference on Resource Adequacy in RTOs/ISOs

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On February 20, 2025, FERC Chairman Mark Christie announced an upcoming Commissioner-led technical conference on resource adequacy in Regional Transmission Organization (“RTO”) and Independent System Operator (“ISO”) regions....more

Troutman Pepper Locke

FERC Holds Technical Conference on Large Loads Co-Locating at Generating Facilities

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On November 1, 2024, FERC Commissioners led a technical conference at their headquarters in Washington, DC, on issues pertaining to co-locating large loads at generating facilities. FERC Commissioners asked questions of...more

Holland & Knight LLP

First Look: FERC Discusses Co-Location of Large Loads

Holland & Knight LLP on

Co-located load – will it help keep the lights on when the impending onslaught of new electrical load hits the nation's grid in the upcoming years? Questions regarding an aging grid that is being stretched thin and whether...more

Troutman Pepper Locke

FERC Accepts SPP's Proposed Tariff Revisions Allowing Make-Whole Payments

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On September 19, 2024, FERC approved Southwest Power Pool, Inc.’s (“SPP”) proposed tariff revisions allowing make-whole payments for incremental energy costs for offers affected by the incremental energy offer cost caps...more

Womble Bond Dickinson

Addressing Inefficiencies in the Energy Sector: The Proposed Energy Permitting Reform Act of 2024

Womble Bond Dickinson on

The permitting process has been identified by numerous commentators as a major cause of delays in the development of energy, infrastructure, and mining projects in the United States. ...more

Dorsey & Whitney LLP

Energy Law: Month in Review - June 2024

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Welcome to Dorsey’s Energy Law: Month in Review. We provide this update to our clients to identify significant developments in the previous month. ...more

Husch Blackwell LLP

FERC Initiates Section 206 Investigation Into RTO “Self Fund” Policy

Husch Blackwell LLP on

On June 13, 2024, the Federal Energy Regulatory Commission (FERC) issued an “Order to Show Cause” (Order) under Section 206 of the Federal Power Act to four regional transmission organizations (RTOs) and independent system...more

Stoel Rives - Renewable + Law

Stakeholders Express Concern That CAISO’s Interconnection Scoring Criteria May Prioritize Load-Serving Entity Selection

The California Independent System Operator’s (CAISO) recently issued Interconnection Process Enhancements (IPE) final proposal provides heightened requirements to complete an interconnection request and relies on scoring...more

Vinson & Elkins LLP

Four Key Predictions for FERC’s 2024 Electricity Agenda

Vinson & Elkins LLP on

Over the past few years, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) and the Department of Energy (“DOE”) have proposed many rules to support the Biden Administration’s push to build transmission...more

Vinson & Elkins LLP

Antitrust Issues in Renewable Energy - November 2023

Vinson & Elkins LLP on

Participants in the renewable energy industry should be aware of antitrust and competition rules because renewable energy is no longer a nascent field. Europe generated almost 40% of its electricity from renewable sources in...more

Troutman Pepper Locke

FERC Accepts ISO-NE’s Proposal to Treat Electric Storage Facilities as Transmission-Only Assets

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On October 19, 2023, FERC accepted ISO New England Inc.’s (“ISO-NE”) proposal to allow electric storage facilities to be planned and operated as transmission-only assets (“SATOAs”) to address system needs identified in the...more

Akin Gump Strauss Hauer & Feld LLP

FERC Proposes to Streamline EQR Data Collection and Filing Process

On October 19, 2023, the Federal Energy Regulatory Commission (FERC or the Commission) proposed changes to the method of collection and data being collected in its Electric Quarterly Reports (EQRs).1 Specifically, FERC...more

Holland & Knight LLP

In Blow to Renewables, Ninth Circuit Mostly Upholds FERC's PURPA Reforms

Holland & Knight LLP on

The U.S. Court of Appeals for the Ninth Circuit on Sept. 5, 2023, issued a critical ruling upholding certain reforms the Federal Energy Regulatory Commission (FERC) issued in 2020 to its regulations implementing the federal...more

Bracewell LLP

FERC Finalizes Interconnection Queue Reforms

Bracewell LLP on

On July 28, 2023, following up on its June 2022 Notice of Proposed Rulemaking (“Generator Interconnection Reform NOPR”), the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued its long-awaited rulemaking...more

Troutman Pepper Locke

FERC Adopts Regulations to Permit Credit-Related Information Sharing

Troutman Pepper Locke on

On June 15, 2023, FERC issued Order No. 895, adopting new regulations permitting regional transmission organizations (“RTO”) and independent system operators (“ISO”) to share, amongst each other, credit-related information of...more

Troutman Pepper Locke

FERC Partially Accepts ISO-NE Order No. 2222 Compliance Filing, but Expresses Concern that Proposal Could Create Undue Barrier to...

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On March 1, 2023, FERC partially approved ISO New England’s (“ISO-NE”) proposed tariff revisions in compliance with Order No. 2222, which removed barriers to the participation of distributed energy resource (“DER”)...more

Nutter McClennen & Fish LLP

Massachusetts Proposes Regional Clean Energy Market

Last week, on the final day of the outgoing Baker Administration, the Massachusetts Department of Energy Resources (DOER) released a new proposal for a regional clean energy market. If implemented, this market would be a new...more

Troutman Pepper Locke

FERC Conditionally Accepts PJM Interconnection Reforms for a First-Ready, First-Served Clustered Cycle Approach

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On November 29, 2022, FERC conditionally accepted PJM Interconnection, L.L.C.’s (“PJM”) tariff revisions to transition from a serial first-come, first-served generator interconnection queue process to a first-ready,...more

Troutman Pepper Locke

FERC Issues Show Cause Order and NOPR on Credit Risk

Troutman Pepper Locke on

On July 28, 2022, FERC issued a show cause order indicating that several regional transmission organization (“RTO”) and independent system operator (“ISO”) tariffs appear to be unjust and unreasonable because they lack...more

Troutman Pepper Locke

FERC Proposes a New, Broader Duty of Candor Rule

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On July 28, 2022, FERC proposed a new “duty of candor” rule that would broadly apply to “all entities communicating with the Commission or other specified organizations related to a matter subject to the jurisdiction of the...more

Holland & Knight LLP

FERC Proposes Allowing RTOs, ISOs to Share Credit Details on Market Participants

Holland & Knight LLP on

The Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) on July 28, 2022, that would permit regional transmission organizations (RTO) and independent system operators (ISO) to share among...more

Bracewell LLP

FERC Renews Focus on Order No. 860 Database Compliance

Bracewell LLP on

Federal Energy Regulatory Commission’s (“FERC’s”) Order No. 860 required all entities authorized by FERC to sell electric energy, capacity, and/or ancillary services at market-based rates (“MBR Sellers”) to submit baseline...more

Troutman Pepper Locke

Summary of FERC Interconnection NOPR

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On June 16, FERC issued a Notice of Proposed Rulemaking (NOPR) focused on updating procedures for interconnecting large generating facilities (20MW and above) and small generating facilities (under 20MW). The NOPR proposes...more

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