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D.C. Circuit Upholds PJM’s $12 Million Nonperformance Penalties Against Energy Harbor for Failing to Perform When Called Upon...

On July 11, 2025, the D.C. Circuit upheld PJM Interconnection L.L.C.’s (“PJM”) assessment of $12 million in penalties against Energy Harbor, LLC (“Energy Harbor”) for failing to perform when called upon by PJM during a major...more

Order No. 1920-B Affirms FERC’s Long-Term Transmission Planning and Cost Allocation Rule

On April 11, 2025, FERC issued Order No. 1920-B, which clarified and maintained key requirements from Order No. 1920-A regarding long-term transmission planning and cost allocation. FERC clarified that transmission providers...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

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 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

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

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

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

New Opportunities for Boosting Grid Security [Video]

Recent rulemaking on cybersecurity by the FERC underscores the importance of managing grid stability and security. In this video, Troutman Pepper Associates Miles Kiger and Jennifer Panahi discuss FERC’s new rate incentives...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

FERC Commissioner Christie Renews Concerns Over Transmission Rate Incentives in MISO Transmission Expansion Plan Order

On January 31, 2023, the Federal Energy Regulatory Commission (“Commission” or “FERC”) granted Great River Energy’s (“GRE”) requested incentive rate treatment for GRE’s investment in the Iron Range Project and Big Stone...more

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