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Energy Sector ISOs Federal Energy Regulatory Commission

Holland & Knight LLP

First Look: FERC Discusses Co-Location of Large Loads

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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

Womble Bond Dickinson

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

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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

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

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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

Holland & Knight LLP

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

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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

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

Troutman Pepper

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

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 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

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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

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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

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

Troutman Pepper

A Divided FERC Accepts ISO-NE’s Request to End its MOPR in Two Years

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On May 27, 2022, a divided FERC ultimately agreed to allow ISO New England Inc. (“ISO-NE”) to sunset its current minimum offer price rule (“MOPR”) as part of its capacity market. During the next two capacity auctions, ISO-NE...more

Stoel Rives - Renewable + Law

FERC Approves Changes to CAISO Interconnection Procedures; Next Queue Cluster Application Window Not Scheduled to Open Until 2023

On September 24, 2021, the Federal Energy Regulatory Commission issued an order (176 FERC ¶ 61,207) approving tariff revisions to amend the California ISO’s (CAISO) interconnection procedures for its current queue cluster...more

Stoel Rives - Renewable + Law

FERC Grants Limited Waiver to the CAISO to Immediately Interconnect Gas Turbines

In the wake of Governor Newsom’s July 30, 2021 Emergency Proclamation intended to mitigate the strain on the California energy grid, the California Department of Water Resources (CDWR) and the California Energy Commission...more

Holland & Knight LLP

New Federal Energy Regulatory Commission Rules on Market-Based Rates Coming Soon

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Starting this fall, the Federal Energy Regulatory Commission (FERC) will implement new rules affecting wholesale electricity sellers that have obtained (or will obtain) market-based rate (MBR) authority from the Commission....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

Vinson & Elkins LLP

FERC Issues White Paper On “Hybrid Resources” Seeking Comments

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On May 26, 2021, the Staff of the Federal Energy Regulatory Commission (“FERC”) issued a “Hybrid Resources White Paper” (“White Paper”) in what may be a first step by Chairman Richard Glick toward policy initiatives to...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

Troutman Pepper

FERC Proposes Reforms to RTO Participation Incentive in Supplemental NOPR

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On April 15, 2021, FERC issued a Notice of Proposed Rulemaking (“NOPR”) to supplement the March 2020 NOPR regarding its electric transmission incentive policy under Federal Power Act (“FPA”) section 219 (see March 23, 2020...more

Holland & Knight LLP

Full Speed Ahead: FERC Reaffirms Distributed Resource Entry into Regional Energy Markets

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On March 18, 2021, in Order 2222-A, the Federal Energy Regulatory Commission (FERC) largely reaffirmed its seminal Order 2222, which dramatically relaxed barriers to aggregated distributed energy resource (DER) participation...more

Husch Blackwell LLP

FERC Explores Barriers To “Hybrid Resources”

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FERC is in the process of gathering information and building a public record on technical and market issues that are prompted by the growing interest in “hybrid resources.” FERC held a technical conference in the summer of...more

Troutman Pepper

Upcoming FERC Workshops and Technical Conferences

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FERC is hosting a number of workshops and technical conferences over the next several months. These include the Resource Adequacy technical conference; Listening Tour for the Office of Public Participation; workshop on...more

Troutman Pepper

House Introduces CLEAN Future Act – A Comprehensive Bill to Achieve A Net Zero Greenhouse Gas Economy by 2050

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On March 2, 2021, members of the United States House of Representatives introduced H.R.1512, the Climate Leadership and Environmental Action for our Nation’s Future Act (“CLEAN Future Act”). The CLEAN Future Act, aims to...more

Troutman Pepper

FERC Directs Informational Reports on Hybrid Resources from RTOs and ISOs Following Technical Conference

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On January 19, 2021, FERC directed Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”) to submit informational reports regarding four hybrid resources issues: (1) terminology; (2)...more

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