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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

Fifth Circuit Finds ANR Pipeline’s Tariff Does Not Require Simultaneous Delivery for Short-Notice Shipments

On May 22, 2025, the U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) addressed a dispute between ANR Pipeline Company (“ANR”) and FERC. The case centered on the interpretation of ANR’s tariff and whether it...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

FERC Denies Complaint Over $23 Million in Network Upgrade Costs

On March 20, 2025, FERC denied Ponderosa Power, LLC’s (“Ponderosa”) complaint alleging that NorthWestern Corporation’s (“NorthWestern”) application of its large generator interconnection procedures (“LGIP”) was unjust and...more

FERC Approves CAISO Revisions to Wheeling Through Priority Tariff Provisions, Amending ATC Calculations to Account for...

On October 30, 2023, FERC accepted the California Independent System Operator Corporation’s (“CAISO”) revisions to its wheeling tariff provisions. The revised provisions allow external load serving entities to obtain, in...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

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