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Laura Swett and David LaCerte Nominated for Federal Energy Regulatory Commission Commissioner Seats

On June 2, 2025, President Donald Trump announced the nomination of Laura Swett to occupy the Federal Energy Regulatory Commission (“FERC”) seat previously held by Chairman Mark Christie. Following this, on July 16, 2025,...more

Ninth Circuit Upholds FERC’s Denial of RTO Incentive Adder for California Utilities Due to Mandatory CAISO Participation

On July 11, 2025, the U.S. Court of Appeals for the Ninth Circuit (“Ninth Circuit”) issued an opinion in Pacific Gas & Electric Company v. FERC, addressing a challenge by Pacific Gas & Electric Company (“PG&E”), Southern...more

On Rehearing, FERC Upholds Approval of PJM’s Proposed Offer Cap Tariff Revisions

On June 26, 2025, FERC upheld PJM Interconnection, L.L.C.’s (“PJM”) proposal to revise its Capacity Performance Quantifiable Risk (“CPQR”) Offer Cap. Several public interest organizations and PJM’s Independent Market Monitor...more

FERC Staff Releases 2025 Summer Energy Market and Electric Reliability Assessment

On May 15, 2025, the FERC’s Office of Energy Policy and Innovation, in coordination with the Office of Electric Reliability, released their 2025 Summer Energy Market and Electric Reliability Assessment, highlighting key...more

FERC Enforces “Rule of Reason,” Requiring CAISO to Embed Business Practice Manual Provision in Tariff

On April 29, 2025, FERC partially granted rehearing in the case of Cometa Energia, S.A. de C.V. (“Saavi”) against the California Independent System Operator Corporation (“CAISO”), finding a provision of CAISO’s Business...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

Petitioners Seek FERC Clarification Regarding Jurisdiction Over Proposed Storage-Based Transmission Project Between Puerto Rico...

On February 10, 2025, Pluvia LLC (“Pluvia”) filed a petition for a declaratory order, asking FERC to clarify its jurisdiction to issue a preliminary permit for the construction, operation, and maintenance of transmission...more

FERC Issues Final Rule on Clean Water Act Section 401 Water Quality Certification Requirements

On November 21, 2024, the Federal Energy Regulatory Commission (“FERC”) issued a final rule establishing a categorical one-year “reasonable period of time” for certifying authorities to act on requests for water quality...more

FERC Issues Notice of Proposed Rulemaking to Conform to EPA’s Recent CWA § 401 Rule

At its May 23, 2024 open meeting, the Federal Energy Regulatory Commission (“FERC”) issued a Notice of Proposed Rulemaking (“NOPR”) proposing to establish a one-year “reasonable period of time” for certifying authorities to...more

FERC Issues Notice of Proposed Rulemaking to Conform to EPA’s Recent CWA 401 Rule

At its May 23 open meeting, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR), proposing to establish a one-year “reasonable period of time” for certifying authorities to act on...more

Senate Committee Considers Three New FERC Nominees

On March 21, 2024, the Senate Committee on Energy and Natural Resources held a hearing to consider President Biden’s three recent nominations to the Federal Energy Regulatory Commission (“FERC” or “Commission”): (1) David...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

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 Reverses Course, Rejects SPP Byway Cost Allocation Proposal for Second Time

On July 13, 2023, FERC on rehearing set aside its prior order that had accepted Southwest Power Pool, Inc.’s (“SPP”) proposal to establish a case-by-case process to allocate, on a regional, postage-stamp basis, all of the...more

FERC Establishes Revised Accounting Rules to Address Renewables, Storage, and RECs

Introduction - On June 29, the Federal Energy Regulatory Commission (FERC or Commission) issued Order No. 898, a final rule that revises FERC’s Uniform System of Accounts (USofA) by adding functional detail concerning the...more

House Subcommittee Holds FERC Oversight Hearing on Improving Reliability Through Energy Expansion, Interregional Transmission, and...

On June 13, 2023, the House of Representatives Subcommittee on Energy, Climate, and Grid Security held a hearing on the “Oversight of FERC: Adhering to a Mission of Affordable and Reliable Energy for America.” The hearing...more

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