News & Analysis as of

ISO/RTO Energy Sector

Paul Hastings LLP

State of Electric Interconnection and Transmission Regulation: Staying Alert to Imminent Developments and Getting Involved -...

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Update: Order No. 2023-A was published in the Federal Register on April 16, 2024. Compliance filings to Order Nos. 2023 and 2023-A are due on May 16, 2023 The electric industry is in the midst of a period of significant...more

Paul Hastings LLP

State of Electric Interconnection and Transmission Regulation: Staying Alert to Imminent Developments and Getting Involved

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The electric industry is in the midst of a period of significant growth and change. Last year, the Federal Energy Regulatory Commission (FERC or Commission) issued its landmark Order No. 2023 that enacted sweeping reforms to...more

Morgan Lewis

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

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Regulatory developments include FERC’s orders on electric storage resources participating in the wholesale markets, qualifying facility eligibility, and reliability rules for inverter-based resources....more

Morgan Lewis - Power & Pipes

2023 FERC Enforcement Report: Continued Focus on Fraud, Manipulation, Market Integrity

The US Federal Energy Regulatory Commission (FERC or Commission) has released its annual report on enforcement for fiscal year 2023. As in fiscal year 2022, FERC’s Office of Enforcement (OE) focused on matters involving fraud...more

K&L Gates LLP

Order No. 2023: Interconnection Reform is Finally Here

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On 28 July 2023, the Federal Energy Regulatory Commission (FERC) issued Order No. 2023, implementing reforms to its generator interconnection agreements and procedures aimed at alleviating the backlog of generation and...more

Troutman Pepper

Electricity Markets: A Regional Perspective

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As the U.S. electricity sector continues to evolve, so too do regional electricity markets across the country. In this video, Troutman Pepper Partners Adrienne Thompson and Chris Jones provide a thorough overview of these...more

Troutman Pepper

Troutman Pepper Summary of FERC Order No. 2023 on Generator Interconnection Reform

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On July 28, the Federal Energy Regulatory Commission (FERC or the Commission) issued Order No. 2023 (Order No. 2023 or Final Rule), which updates the procedures for interconnecting large generating facilities (20MW and above)...more

Troutman Pepper

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

Morgan Lewis

Storage Participation in Wholesale Markets

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Regulatory developments include FERC’s orders on electric storage resources participating in the wholesale markets, qualifying facility eligibility, and reliability rules for inverter-based resources....more

Troutman Pepper

FERC Issues Show Cause Order and NOPR on Credit Risk

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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

FERC Upholds PJM Reserve Market Changes, Clarifies Chairman’s Role to Oversee Major Litigation Decisions

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On July 28, 2022, FERC upheld changes to PJM Interconnection, L.L.C.’s (“PJM”) Reserve Market that it first required in a December 2021 order on voluntary remand from the U.S. Court of Appeals for the District of Columbia...more

K&L Gates LLP

Lessons To Be Learned from FERC's Investigation of a New Power Project's Participation in the New England Capacity Market

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On 28 June 2022, the Federal Energy Regulatory Commission (FERC) issued an order approving a Stipulation and Consent Agreement stemming from an enforcement investigation with Salem Harbor Power Development, LP (Salem Harbor...more

Clark Hill PLC

FERC Proposes Major Interconnection Reforms to Facilitate Renewable Energy Growth

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On June 16, the Federal Energy Regulatory Commission (FERC) issued a proposed rulemaking designed to update key aspects of its pro forma interconnection procedures. FERC designed these reforms “to address interconnection...more

Troutman Pepper

Declining to Propose a Generic Solution, FERC Directs RTOs/ISOs to File Reports on System Needs

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On April 21, 2022, FERC directed each RTO/ISO to submit information related to their wholesale markets, including how changing resource mixes and load profiles are affecting system needs. FERC stated it will review the...more

Morgan Lewis - Power & Pipes

FERC Orders RTOs/ISOs to Report on System Needs in Effort to Modernize Market Design

To address changing system needs, FERC ordered each Regional Transmission Organization and Independent System Operator (collectively, RTO/ISO) to submit information to the Commission regarding changes to wholesale markets...more

Pierce Atwood LLP

DER Aggregations in RTO/ISO Markets: An Update on FERC Order No. 2222 Compliance and Implementation

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In September of 2020, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued Order No. 2222, requiring Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”) to adopt rules...more

K&L Gates LLP

Energy Storage Handbook 2022

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The K&L Gates Power practice is pleased to present the latest edition of the Energy Storage Handbook. This handbook is an annually updated primer on what energy storage is, how it is regulated by U.S. federal and state...more

Troutman Pepper

FERC Issues Final Rule on Transmission Line Ratings

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On December 16, 2021, the Commission issued its final rule on transmission line ratings that reforms both the pro forma Open Access Transmission Tariff (“OATT”) and the Commission’s corresponding regulations in an effort to...more

Troutman Pepper

FERC Staff Issues Whitepaper on Energy and Ancillary Services Market Reforms Ahead of Technical Conferences

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On September 7, 2021, FERC staff issued a whitepaper to frame discussions ahead of two technical conferences planning to discuss potential anscillary services reforms. The whitepaper summarizes approaches that RTOs/ISOs are...more

Bracewell LLP

FERC Endeavors to Encourage Transmission Development in Coordination With States

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At the June 17, 2021 Open Meeting, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a policy statement and an order reflecting its continued support for transmission project development and...more

Troutman Pepper

FERC Issues Order No. 2222-B, Setting Demand Response Opt-Out for Further Consideration

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On June 17, 2021, FERC set aside its previous decision in Order No. 2222-A that allowed state regulatory authorities to prohibit demand response resources from participating in distributed energy resource (“DER”) aggregations...more

Davis Wright Tremaine LLP

FERC Encourages Development of New Transmission Infrastructure Through Federal-State Cooperation

The Federal Energy Regulatory Commission (FERC) took steps in a recent Order and Policy Statement to improve collaboration with states on electric transmission development and to promote use of alternative models for project...more

Bracewell LLP

FERC Staff Issues White Paper on Hybrid Resources; Seeks Industry Input

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On May 26, 2021, Federal Energy Regulatory Commission (“FERC”) staff issued a white paper regarding the current status and use of hybrid resources – e.g., co-located generation and storage facilities – in wholesale markets,...more

Troutman Pepper

FERC Issues Policy Statement on Carbon Pricing in Organized Wholesale Electric Markets

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On April 15, 2021, FERC issued a long-awaited policy statement providing guidance on incorporating state-determined carbon pricing into organized markets operated by Regional Transmission Organizations (“RTOs”) and...more

Davis Wright Tremaine LLP

FERC Changes Course on Proposed Electric Transmission Incentives Policy

The Federal Energy Regulatory Commission's March 20, 2020, Notice of Proposed Rulemaking (NOPR) in Docket No. RM20-10-000 proposed several changes to the Commission's electric transmission incentives policy under Section 219...more

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