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FERC Temporarily Raises Cost Limits for Blanket Certificate Pipeline Projects to $61.65 Million

On June 18, 2025, FERC temporarily raised the cost limits for blanket certificate natural gas pipeline projects constructed and placed into service by May 31, 2027, from $41 million to $61.65 million. Citing what it called a...more

FERC Announces Commissioner-led Technical Conference on Resource Adequacy in RTOs/ISOs

On February 20, 2025, FERC Chairman Mark Christie announced an upcoming Commissioner-led technical conference on resource adequacy in Regional Transmission Organization (“RTO”) and Independent System Operator (“ISO”) regions....more

FERC Reinstates Authorization for Transco Pipeline Expansion Project

On January 24, 2025, FERC reinstated a certificate of public convenience and necessity (“CPCN”) for Transcontinental Gas Pipe Line Company’s (“Transco”) Regional Energy Access Expansion Project (“Project”) after the D.C....more

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

On November 21, 2024, FERC issued Order No. 1920-A, which modified Order No. 1920 to expand the states’ roles in long-term transmission planning and clarified requirements for such planning as set forth in Order No. 1920....more

Federal Appeals Court Appears Skeptical of State’s Ability to Question Federal Transmission Planning Decisions

On December 5, 2024, the U.S. Court of Appeals for the Third Circuit heard oral arguments in Transource Pennsylvania LLC v. Steven M. Defrank, et.al. The case presents the question of potential tension between FERC’s...more

FERC Chief Accountant Proposes to Modify Transferability of Income Tax Credits

On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more

FERC Holds Workshop on Innovations & Efficiencies in Generator Interconnection Process, Seeks Comments

On September 10 and 11, 2024, FERC staff held a two-day workshop at its headquarters in Washington, DC on opportunities to further refine the generator interconnection queue process. Panelists and FERC staff discussed...more

FERC Dismisses Lackawanna Complaint Against PJM Seeking “Stability Limit”-Related Lost Opportunity Costs

On May 23, 2024, FERC issued an Order denying Lackawanna Energy Center LLC’s (“Lackawanna”) complaint against PJM Interconnection, L.L.C. (“PJM”) alleging that PJM failed to reimburse Lackawanna for lost opportunity costs...more

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

MISO Submits FERC Filing Seeking to Reform Resource Accreditation Requirements

On March 28, 2024, the Midcontinent Independent System Operator, Inc. (“MISO”) submitted a filing to the Federal Energy Regulatory Commission (“FERC”) proposing revisions to its Open Access Transmission, Energy and Operating...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 Extreme Cold Weather Reliability Standards EOP-011-4 and TOP-002-5

On February 15, 2024, FERC approved two new extreme cold weather Reliability Standards EOP-011-4 (Emergency Operations) and TOP-002-5 (Operations Planning)....more

Sixth Circuit Finds that FERC Overstepped its Authority on Voluntary Remand of PJM Reserve Market Design Changes

On December 19, 2023, the U.S. Court of Appeals for the Sixth Circuit (“Sixth Circuit”), in Electric Power Supply Association; PJM Power Providers Group v. FERC, held that the former Chair of the Federal Energy Regulatory...more

FERC Conditionally Approves CAISO Market Expansion

On December 20, 2023, FERC approved the California Independent System Operator Corporation’s (“CAISO”) proposal to establish the Extended Day Ahead Market (“EDAM”), which allows external Balancing Authority Areas (“BAAs”) to...more

FERC Finds Dominion LNG Back-up Fuel Project Satisfies Hinshaw Exemption Under the NGA

On November 16, 2023, FERC granted Virginia Electric and Power Company d/b/a Dominion Energy Virginia’s (“Dominion”) petition requesting the Commission declare that Dominion’s planned liquefied natural gas (“LNG”) production,...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 Directs PJM to Use a Historical Simulation Model with a 99% Confidence Level for its FTR Credit Requirement

On September 21, 2023, the Commission approved, in part, PJM Interconnection L.L.C.’s (“PJM”) proposed tariff revisions regarding the calculation of the Financial Transmission Right (“FTR”) credit requirement (“September...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

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