News & Analysis as of

RTO Federal Energy Regulatory Commission Electricity

Akin Gump Strauss Hauer & Feld LLP

FERC Holds Technical Conference to Explore Resource Adequacy Challenges

On June 4–5, 2025, the Federal Energy Regulatory Commission (FERC or Commission) hosted a commissioner-led technical conference to discuss resource adequacy challenges facing regional transmission organizations and...more

Troutman Pepper Locke

FERC Reaffirms MISO Interconnection Queue Cap on Rehearing

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On May 27, 2025, FERC addressed arguments raised on rehearing of a January 30, 2025 order, which accepted the Midcontinent Independent System Operator, Inc.’s (“MISO”) proposal to modify its generator interconnection study...more

Womble Bond Dickinson

FERC's Co-Location Conundrum: Balancing Grid Reliability with Data Center Development as PJM's Tariff Faces Scrutiny

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FERC's Order Signals Transformative Change While Navigating Jurisdictional Limits: While FERC recognizes the urgent need to address co-location arrangements (particularly given the AI/data center boom), the intricate...more

Troutman Pepper Locke

FERC Approves SPP’s RTO West Plan to Connect Eastern and Western Grids

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On March 30, 2025, FERC approved revisions to Southwest Power Pool, Inc.’s (“SPP”) Open Access Transmission Tariff (“Tariff”) and Governing Documents to allow nine entities (“Expansion Members”) in the Western Interconnection...more

Morgan Lewis

How Recent FERC Orders Are Regulating Electric Storage, QFs, and Inverter-Based Resources in 2025

Morgan Lewis on

Regulatory developments include FERC’s actions on electric storage resources participating in the wholesale markets, co-location of large electric loads, qualifying facility eligibility, and reliability rules for...more

Troutman Pepper Locke

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

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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

Troutman Pepper Locke

FERC Holds Technical Conference on Large Loads Co-Locating at Generating Facilities

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On November 1, 2024, FERC Commissioners led a technical conference at their headquarters in Washington, DC, on issues pertaining to co-locating large loads at generating facilities. FERC Commissioners asked questions of...more

Womble Bond Dickinson

Addressing Inefficiencies in the Energy Sector: The Proposed Energy Permitting Reform Act of 2024

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The permitting process has been identified by numerous commentators as a major cause of delays in the development of energy, infrastructure, and mining projects in the United States. ...more

Troutman Pepper Locke

FERC Adopts Regulations to Permit Credit-Related Information Sharing

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On June 15, 2023, FERC issued Order No. 895, adopting new regulations permitting regional transmission organizations (“RTO”) and independent system operators (“ISO”) to share, amongst each other, credit-related information of...more

Troutman Pepper Locke

FERC Approves Regional Resource Adequacy Program in the Western Interconnection

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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

Troutman Pepper Locke

FERC Issues Show Cause Order and NOPR on Credit Risk

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On July 28, 2022, FERC issued a show cause order indicating that several regional transmission organization (“RTO”) and independent system operator (“ISO”) tariffs appear to be unjust and unreasonable because they lack...more

Troutman Pepper Locke

FERC Approves ROE Adder for SPP Membership, Prompting Statement from Commissioner Christie

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On May 31, 2022, FERC accepted and set for hearing Southwest Power Pool, Inc.’s (“SPP”) proposal to revise its Open Access Transmission Tariff (“OATT”) to establish a formula rate template (“Formula Rate”) on behalf of...more

Troutman Pepper Locke

FERC Issues Policy Statement on Carbon Pricing in Organized Wholesale Electric Markets

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On April 15, 2021, FERC issued a long-awaited policy statement providing guidance on incorporating state-determined carbon pricing into organized markets operated by Regional Transmission Organizations (“RTOs”) and...more

Troutman Pepper Locke

Virginia Energy Regulation Update - Battery + Storage Podcast (Episode 7)

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Troutman Pepper energy partner Bill Derasmo talks with battery and storage experts from across the industry. The podcast shares the unique perspectives of industry veterans and thought leaders, exploring how they are...more

Morgan Lewis - Power & Pipes

FERC Begins Inquiry on Hybrid Resource Participation in Wholesale Markets

During its January open meeting, FERC issued an order directing independent system operators (ISOs) and regional transmission organizations (RTOs) to submit informational reports regarding co-located generation resources. ...more

Davis Wright Tremaine LLP

FERC Opens the Door to Carbon Pricing in Wholesale Electricity Markets

The Federal Energy Regulatory Commission (FERC) recently took steps to encourage regions to incorporate state carbon pricing policies into wholesale electricity markets. FERC's proposed policy statement comes at a time when...more

Bracewell LLP

FERC Proposes Policy Statement Encouraging RTOs/ISOs to Develop Rules Incorporating State Determined Carbon Prices

Bracewell LLP on

On October 15, 2020, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued a Proposed Policy Statement regarding carbon pricing in organized wholesale electricity markets. In short, the statement...more

Orrick, Herrington & Sutcliffe LLP

FERC Opens Organized Markets to Distributed Energy Resources

At its September 17, 2020, meeting, the Federal Energy Regulatory Commission (“FERC”) issued a groundbreaking order that will enable aggregators of distributed energy resources (“DERs”) located on utility distribution systems...more

Mintz - Energy & Sustainability Viewpoints

FERC Order Removes Barriers for Distributed Energy Resource Aggregations in Wholesale Markets

On September 17, 2020, the Federal Energy Regulatory Commission (“FERC”) issued Order No. 2222 (the “Order”) to allow for the greater participation of distributed energy resource (“DER”) aggregations in organized wholesale...more

Womble Bond Dickinson

Wholesale Markets Opened to Small Energy Producers

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On September 17, 2020, the Federal Energy Regulatory Commission (FERC) made it possible through aggregation for small solar, bio-mass, wind, storage, demand response and other distributed energy resources to bid competitively...more

Morgan Lewis

FERC Breaks New Ground with DER Aggregation Order

Morgan Lewis on

Under Order No. 2222, the Federal Energy Regulatory Commission hopes to “usher in the electric grid of the future” by opening wholesale markets to distributed energy resource aggregations. ...more

Troutman Pepper Locke

FERC Opens Door for Participation of Distributed Energy Resource Aggregations in Wholesale Electric Markets

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On September 17, 2020, FERC issued a final rule (“Order No. 2222”) amending its regulations to require Regional Transmission Organizations and Independent System Operators (“RTO/ISO”) to revise their tariffs to facilitate the...more

Beveridge & Diamond PC

Grid of the Future? FERC Opens the Door to Aggregation of Distributed Energy Resources

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On September 17, 2020, the Federal Energy Regulatory Commission (FERC) adopted Order No. 2222, which paves the way for aggregated distributed energy resources to participate in the nation’s “organized” wholesale electricity...more

Troutman Pepper Locke

FERC Issues Second Notice of Technical Conference on Carbon Pricing in Organized Wholesale Electric Markets

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On August 28, 2020, FERC issued a supplemental Notice of a Commission-led Technical Conference on state pricing for carbon dioxide emissions, commonly referred to as carbon pricing, in FERC-jurisdictional wholesale electric...more

Akin Gump Strauss Hauer & Feld LLP

D.C. Circuit Backs FERC on Electric Storage Rule

The U.S. Court of Appeals for the D.C. Circuit recently upheld the Federal Energy Regulatory Commission’s (FERC or “Commission”) Order No. 841, a 2018 rulemaking addressing electric storage resources. The purpose of Order no...more

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