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D.C. Circuit Vacates FERC’s Approval of Transco’s Pipeline Expansion

On July 30, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) issued an opinion vacating and remanding FERC’s order approving Transcontinental Gas Pipe Line Company’s (“Transco”)...more

FERC Approves MISO’s Use of Downward Sloping Demand Curve in 2025-2026 Planning Resource Auctions

On June 27, 2024, FERC accepted Midcontinent Independent System Operator Inc.’s (“MISO”) proposed tariff revisions that sought to implement a downward-sloping Reliability Based Demand Curve (“RBDC”) in the MISO Planning...more

7/22/2024  /  FERC , MISO , Oil & Gas , Opt-Outs , Tariffs

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

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

Divided FERC Announced Much-Anticipated Transmission Rules

On May 13, 2024, the Commission announced two major transmission reform final rules: Building for the Future Through Electric Regional Transmission Planning and Cost Allocation (“Order No. 1920”) and Applications for Permits...more

Senate introduces bipartisan legislation to give FERC retroactive refund authority under section 5 of the Natural Gas Act.

On April 18, 2024, Senators Richard Blumenthal (D-CT) and Cindy Hyde-Smith (R-MS) introduced the Making Pipelines Accountable to Consumers and Taxpayers Act (“MPACT Act”) (S. 4171) that, if adopted, would grant FERC authority...more

D.C. Circuit upholds FERC orders granting natural gas pipeline companies’ requests to extend project deadlines.

The United States Court of Appeals for the District of Columbia (“D.C. Circuit”) recently upheld two FERC orders granting natural gas pipeline developers’ requests to extend their construction deadlines. The D.C. Circuit...more

Troutman Pepper Summary of FERC Order No. 2023-A on Generator Interconnections

On March 21, the Federal Energy Regulatory Commission (FERC or the Commission) issued Order No. 2023-A (Final Rule), which reaffirmed aspects of Order No. 2023 — the Commission’s landmark order updating its generator...more

FERC Approves Changes to PJM Capacity Accreditation Rules; Rejects Proposed Changes Seeking to Better Reflect Risk in Capacity...

On January 30, 2024, FERC approved, subject to condition, PJM’s proposal to reform its Reliability Pricing Model, including resource adequacy risk modeling, capacity accreditation, testing requirements for capacity resources,...more

FERC Rejects Solar Developer’s Request for Waiver of Security Posting Requirements After Using the Wrong Form; FERC Urges Tariff...

On November 30, 2023, the Commission denied a waiver request and a request for remedial relief from Ridgeview Solar LLC (“Ridgeview Solar”). Ridgeview Solar had sought a waiver or remedial relief from the procedural deadline...more

FERC denies Muni Complaint on Proposed RNG Interconnection Request

On November 30, 2023, the Commission denied the Minnesota Municipal Power Agency’s (“MMPA”) complaint alleging that Northern Natural Gas Company (“Northern”) violated the Natural Gas Act (“NGA”) by refusing to execute an...more

PJM Files Capacity Market Overhaul for Resource Adequacy and Grid Reliability

On October 13, 2023, PJM Interconnection, L.L.C. (“PJM”) submitted two filings with FERC proposing revisions to its Open Access Transmission Tariff (“Tariff”) and its “Reliability Assurance Agreement” (“RAA”) designed to...more

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

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

FERC Accepts Tennessee Gas Pipeline’s New PowerServe Rate Schedule and Authorizes Capacity Lease Agreement with Kinder Morgan

On September 29, 2023, FERC approved Tennessee Gas Pipeline Company, L.L.C.’s (“TGP”) proposal to lease intrastate capacity from Kinder Morgan Texas Pipeline LLC (“Kinder Morgan”) to offer a new hourly transportation...more

After Initiating Credit Risk Show Cause Proceedings in 2022, FERC Finds that CAISO’s, ISO-NE’s, and NYISO’s Tariffs Remain Just...

On September 21, 2023, the Commission issued separate orders on show cause proceedings finding that the existing tariffs of the California Independent System Operator Corporation (“CAISO”), ISO New England Inc. (“ISO-NE”),...more

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

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

Mountain Valley Pipeline To Resume Construction After Supreme Court Vacates Fourth Circuit’s Order Halting Construction

On July 27, 2023, the U.S. Supreme Court vacated the U.S. Court of Appeals for the Fourth Circuit’s decision to grant the Wilderness Society’s motions to stay of construction on the Mountain Valley Pipeline (“MVP”) pending...more

FERC Establishes Revised Accounting Rules to Address Renewables, Storage, and RECs

Introduction - On June 29, the Federal Energy Regulatory Commission (FERC or Commission) issued Order No. 898, a final rule that revises FERC’s Uniform System of Accounts (USofA) by adding functional detail concerning the...more

State Attorneys General Argue BlackRock is Violating its FERC Blanket Authorization

A group of 17 states, through their Attorneys General (“State AGs”), filed a motion (“Motion”) on May 10, 2023, requesting that the Commission audit and investigate whether BlackRock is acting as an “activist” investor,...more

FERC Addresses Social Cost of Carbon and Environmental Justice Analysis on Remand

On remand from the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”), FERC reaffirmed that Rio Grande LNG, LLC’s proposed liquified natural gas (“LNG”) terminal project (“Rio Grande LNG...more

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

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

D.C. Circuit Upholds FERC Interpretation of PURPA Size Limitation Based on “Send out” to Point of Interconnection

On February 14, 2023, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) upheld FERC’s March 2021 order granting Broadview Solar, LLC’s (“Broadview”) hybrid solar and battery project...more

On Rehearing, FERC Upholds Jurisdiction over AECI Emergency Energy Transactions in SPP Market During Winter Storm Uri

On January 19, 2023, FERC issued an order upholding its decision to exercise primary jurisdiction over emergency energy sales between Southwest Power Pool, Inc. (“SPP”) and Associated Electric Cooperative, Inc. (“AECI”)...more

FERC Accepts Arizona Public Service Company’s Proposal to Adopt Flowgate ATC Methodology and Denies Its Request to Waive TTC...

On December 15, 2022, FERC issued an order accepting Arizona Public Service Company’s (“APS”) revisions to its Open Access Transmission Tariff (“Tariff”) that would allow APS to begin using the Flowgate Methodology for...more

Various State Attorneys General Urge FERC to Revoke Vanguard’s Blank Waiver to Acquire Utility Securities

On November 28, 2022, various State Attorneys General intervened to protest (the “Protest”) a filing made by The Vanguard Group, Inc., along with its affiliated entities (collectively, “Vanguard”) requesting to extend the...more

FERC Finds PUHCA Exemptions Appropriate for Holding Company Ownership of Grid-Charging Storage Facilities Selling at Retail

On November 17, 2022, FERC granted a petition for declaratory order (“Petition”) filed by Ameresco, Inc. (“Ameresco”) and its subsidiaries (collectively with Ameresco, “the Ameresco Companies”) requesting exemption from...more

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