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Ninth Circuit Finds that PURPA Gives FERC Broad Implementation Discretion, But Remands New Qualifying Facility Rules for Lack of...

On September 5, 2023, the U.S. Court of Appeals for the Ninth Circuit (“Ninth Circuit”), in Solar Energy Industries Association v. FERC, held that the Public Utility Regulatory Policy Act (“PURPA”) gives FERC broad discretion...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

FERC Approves SPP Proposal for Energy Storage to Be Considered Transmission-Only Assets

On May 26, 2023, the Commission accepted Southwest Power Pool, Inc.’s (“SPP”) proposed revisions to its Open Access Transmission Tariff (“Tariff”) to establish the “framework under which an electric storage resource may be...more

House Republicans Press FERC on Environmental Review Issues

On March 3, 2023, the House Energy and Commerce Committee Chair Cathy McMorris Rodgers (R-WA) and Energy, Climate Change, and Grid Security Subcommittee Chair Jeff Duncan (R-SC) sent a letter to Acting FERC Chairman Willie...more

FERC Commissioners Answer to Senate Committee on Fleet Transformation and Other Pressing Issues

On May 4, 2023, the Senate Energy and Natural Resources Committee hosted all four FERC Commissioners for an oversight hearing to focus on reliability in the face of (1) cyber-attacks, (2) coal and natural gas plant...more

FERC to Convene Forum on PJM Capacity Market

On April 19, 2023, FERC announced it would hold a forum to discuss the PJM Interconnection, L.L.C. (“PJM”) capacity market. The Commissioner-led forum is scheduled for Thursday, June 15, 2023. There will be three panels to...more

FERC Confirms that Orders Under Sections 210 and 211 of the Federal Power Act Would Not Generally Confer “Public Utility”...

On March 16, 2023, FERC granted a petition declaring that, should it issue orders pursuant to Sections 210 and 211 of the Federal Power Act (“FPA”), which would be required for a prospective project to interconnect Puerto...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

FERC Approves Regional Resource Adequacy Program in the Western Interconnection

On February 10, 2023, FERC approved the Western Resource Adequacy Program (“WRAP”) proposed by the Western Power Pool (“WPP”). The voluntary program commits participants to demonstrate prior to a given Winter or Summer season...more

CEQ issues Notice of Interim Guidance on Greenhouse Gas Emissions in NEPA Reviews

On January 9, the White House Council on Environmental Quality (CEQ) issued an Interim Guidance on Consideration of Greenhouse Gas (GHG) Emissions and Climate Change (Interim Guidance) “to assist Federal agencies in their...more

White House Releases New Version of the Climate and Economic Justice Screening Tool

On November 22, 2022, the White House released a new version of the Climate and Economic Justice Screening Tool, an online interactive map that uses datasets on various “burdens” environmental justice communities may face,...more

U.S. Court of Appeals for the 9th Circuit Affirms Lower Court’s Dismissal of Tribe’s Case Against City of Seattle

On December 30, 2022, the U.S. Court of Appeals for the 9th Circuit (“9th Circuit”) affirmed a lower court’s denial of the Sauk-Suiattle Indian Tribe’s (“Tribe”) motion to remand to state court and its dismissal of the...more

Texas Court Finds Lack of Causation in Takings Case Arising from Spills at Texas Dam During Hurricane Harvey

On October 6, the Fourteenth Court of Appeals of Houston, Texas issued an opinion in San Jacinto River Authority v. Gonzalez, et al., a case involving claims by 85 residents against the San Jacinto River Authority...more

D.C. Circuit Vacates FERC Order Approving the Conowingo Dam’s Federal License Renewal

On December 20, 2022, the U.S. Court of Appeals for the D.C. Circuit (“D.C. Circuit”) in Waterkeepers Chesapeake, et al. v. FERC vacated a FERC order approving the relicensing of the Conowingo Dam because FERC did not have...more

DOE Announces $28 Million Funding to Support Hydroelectric Programs

On October 21, 2022, the U.S. Department of Energy (“DOE”) announced three new funding opportunities to support research and development projects for hydropower infrastructure in the United States. The funding totals $28...more

Biden Names Willie Phillips Acting Chairman of FERC

On January 3, 2023, President Joe Biden named Willie Phillips acting chairman of FERC. Chairman Phillips first joined the Commission in December 2021 after being nominated by President Biden and confirmed by the Senate. His...more

FERC Directs NERC to Develop Internal Network Security Monitoring for High and Medium Impact Bulk Electric System Cyber Systems

On January 19, 2023, the Commission issued a final rule that directs the North American Electric Reliability Corporation (“NERC”) to develop and submit reliability standards for monitoring high and medium impact bulk electric...more

FWS Finalizes NLEB Uplisting and Advances Tricolored Bat Listing

Following its March 2022 proposal to uplist the northern long-eared bat (NLEB) to endangered status, U.S. Fish and Wildlife Service (FWS) finalized the proposal on November 30, 2022. In addition, the agency proposed to list...more

FERC Issues Proposed Rule Implementing FPA Amendments in Infrastructure Investment and Jobs Act

On December 15, 2022, FERC issued a Notice of Proposed Rulemaking (“NOPR”) seeking to revise its regulations governing applications for permits to site electric transmission facilities under § 216 of the Federal Power Act...more

FERC Accepts CAISO Proposal to Correct Payment Overcollections by Storage Resources

On November 18, 2022, FERC accepted a September 19, 2022 proposal from the California Independent System Operator (“CAISO”) to correct “excessively high” payments being made to electric storage resources that are forced to...more

12/12/2022  /  CAISO , Energy Sector , Energy Storage , FERC

FERC Issues Proposals Regarding Inverter-Based Resources to Improve Grid Reliability

On November 17, 2022, FERC issued three orders intended to address the reliability impacts of the rapid integration of inverter-based resources (“IBRs”), including solar, wind, fuel cell, and battery storage resources, on the...more

11/28/2022  /  Electricity , Energy Sector , FERC , NERC , Power Grid

Senator Manchin’s Permitting Reform Bill Pulled From the Continuing Resolution

On September 21, Senator Joe Manchin (D-WV), Chairman of the Senate Energy and Natural Resources Committee, released the text of the Energy Independence and Security Act of 2022 (Act). This comprehensive Act was set to be...more

Supreme Court of California Finds FERC License Preempts Challenge to FERC Order

On August 1, the Supreme Court of California upheld a decision by the Court of Appeal, which found that the Federal Power Act (FPA) preempts application of the California Environmental Quality Act (CEQA) when the state is...more

Tenth Circuit Resolves Jurisdictional Dispute, Finds FPA Jurisdictional Limit Does Not Apply to Non-FERC Agency Orders

On September 30, the U.S. Court of Appeals for the Tenth Circuit issued an opinion in Save the Colorado, et al. v. Spellmon. The case arose from various conservation group challenges to the U.S. Army Corps of Engineers...more

DOE Announces $13.5M Distribution to Hydroelectric Facilities Through the Hydroelectric Production Incentive Program

On September 9, the U.S. Department of Energy (DOE) announced that it would distribute $13.5 million to incentivize hydroelectric generation in the United States. The financial support is part of the Hydroelectric Production...more

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