News & Analysis as of

ISO/RTO Federal Energy Regulatory Commission Energy Market

Morgan Lewis

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

Morgan Lewis on

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

Troutman Pepper

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

Troutman Pepper on

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...

Troutman Pepper on

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

Morgan Lewis on

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

Troutman Pepper 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

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

Troutman Pepper on

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

Troutman Pepper

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

Troutman Pepper on

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

Pierce Atwood LLP

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

Pierce Atwood LLP on

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

Troutman Pepper

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

Troutman Pepper on

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

Troutman Pepper

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

Troutman Pepper on

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 to Allow Distributed Energy Resource Aggregations in Wholesale Electric Markets to Include Demand Response Resources

Troutman Pepper on

On March 18, 2021, FERC issued Order No. 2222-A, setting aside its finding in Order No. 2222 that demand response resource participation in heterogeneous distributed energy resource (“DER”) aggregations are subject to the...more

Akin Gump Strauss Hauer & Feld LLP

FERC Seeks Information from RTOs/ISOs on Hybrid (Generation + Storage) Resources

On January 19, 2021, the Federal Energy Regulatory Commission (FERC) directed the nation’s six Regional Transmission Organizations and Independent System Operators (RTOs/ISOs) to submit reports on the integration of “hybrid”...more

Troutman Pepper

Commissioners Clash Over Proposed Policy Statement on Carbon Pricing

Troutman Pepper on

On October 15, 2020, FERC issued a notice of proposed policy statement on state-determined carbon pricing in wholesale markets that clarified the agency’s jurisdiction over wholesale market rules incorporating...more

Mintz - Energy & Sustainability Viewpoints

FERC Order Removes Barriers for Distributed Energy Resource Aggregations in Wholesale Markets

On September 17, 2020, the Federal Energy Regulatory Commission (“FERC”) issued Order No. 2222 (the “Order”) to allow for the greater participation of distributed energy resource (“DER”) aggregations in organized wholesale...more

Womble Bond Dickinson

Wholesale Markets Opened to Small Energy Producers

Womble Bond Dickinson on

On September 17, 2020, the Federal Energy Regulatory Commission (FERC) made it possible through aggregation for small solar, bio-mass, wind, storage, demand response and other distributed energy resources to bid competitively...more

Troutman Pepper

FERC Opens Door for Participation of Distributed Energy Resource Aggregations in Wholesale Electric Markets

Troutman Pepper on

On September 17, 2020, FERC issued a final rule (“Order No. 2222”) amending its regulations to require Regional Transmission Organizations and Independent System Operators (“RTO/ISO”) to revise their tariffs to facilitate the...more

Holland & Knight LLP

Federal Energy Regulatory Commission Order Opens Competitive Markets for Distributed Resources

Holland & Knight LLP on

On Sept. 17, 2020, the Federal Energy Regulatory Commission (FERC) approved Order No. 2222 and forged a new path forward for the nation's wholesale energy markets, which will soon welcome participation from distributed energy...more

Davis Wright Tremaine LLP

FERC Denies PJM's Effort to Limit Authority of its Independent Market Monitor

The Federal Energy Regulatory Commission (FERC) recently thwarted an effort by PJM Interconnection LLC to limit the ability of its Independent Market Monitor (IMM) to file complaints against PJM. The Commission ruled that the...more

Davis Wright Tremaine LLP

FERC Acts on Price Formation in Organized Markets; Requires Revision to Pricing Rules for Fast-start Resources in PJM and NYISO

In June 2014, the Federal Energy Regulatory Commission initiated a review of price formation in energy and ancillary services markets operated by regional transmission organizations and independent system operators....more

K&L Gates LLP

Energy Storage Handbook Vol. 4

K&L Gates LLP on

The power practice has updated the popular resource, the Energy Storage Handbook. This Energy Storage Handbook (Handbook) is designed to be a basic primer on what energy storage is, how it is regulated by federal and state...more

K&L Gates LLP

Energy Storage Handbook Vol. 2

K&L Gates LLP on

Designed as a basic primer on what energy storage is, how it is regulated and what sorts of issues are encountered when such projects are financed and developed, the Handbook is intended to highlight the most common...more

Stoel Rives - Renewable + Law

5 Key Takeaways from FERC’s Recent Energy Storage Order

In February, FERC issued Order 841, Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators (the “Order”), requiring RTOs and ISOs to establish new market...more

Morrison & Foerster LLP

New FERC Rules Open the Door Wider for Electric Storage Participation in Wholesale Electricity Markets, and Establish Primary...

On February 15, 2018, the Federal Energy Regulatory Commission (FERC) voted unanimously to issue a highly anticipated final rule that directs regional grid operators to remove barriers to the participation of electric storage...more

Morgan Lewis

Landmark FERC Rule Paves Way for Electric Storage in Wholesale Markets

Morgan Lewis on

Last week, the Federal Energy Regulatory Commission issued its long-awaited final rule that aims to remove barriers to electric storage resource participation and enhance competition in regional transmission organization and...more

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