News & Analysis as of

ISO/RTO Wholesale 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

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

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

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

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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 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

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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

K&L Gates LLP

Energy Storage Handbook Vol. 4

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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

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

K&L Gates LLP

Energy Storage Handbook

K&L Gates LLP on

As of today, approximately 800 MW of advanced energy storage technologies have been deployed in the United States, with nearly all of that capacity coming online in the last decade. New technologies, use cases, and...more

Morrison & Foerster LLP

FERC Proposes Rules on Electric Storage and Distributed Energy Resource Participation in Organized Wholesale Power Markets,...

Morrison & Foerster LLP on

FERC issued a proposed rule last week that has the potential to blaze a path forward for electric storage and distributed energy resources in organized wholesale electricity markets. It also released its annual enforcement...more

Morgan Lewis

FERC Proposes to Integrate Electric Storage into Organized Markets

Morgan Lewis on

The proposed rule recognizes the physical and operational characteristics of electric storage resources and distributed energy resource aggregators and removes barriers to their participation in organized wholesale electric...more

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