News & Analysis as of

RTO ISO/RTO Federal Energy Regulatory Commission

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 Issues Show Cause Order and NOPR on Credit Risk

Troutman Pepper Locke on

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 Issues Order No. 2222-B, Setting Demand Response Opt-Out for Further Consideration

Troutman Pepper Locke on

On June 17, 2021, FERC set aside its previous decision in Order No. 2222-A that allowed state regulatory authorities to prohibit demand response resources from participating in distributed energy resource (“DER”) aggregations...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

FERC Holds a Technical Conference on Carbon Pricing in Organized Markets

Troutman Pepper Locke on

On September 30, 2020, FERC held a technical conference focusing on how state-adopted carbon pricing intersects with a Regional Transmission Organization/Independent System Operator (“RTO/ISO”) administered market, and...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

Womble Bond Dickinson on

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

White & Case LLP

Opting In (or Out): FERC’s Approach to Integrating Electric Storage and Distributed Energy Resources

White & Case LLP on

In a breakthrough final rule, the Federal Energy Regulatory Commission carves out space in wholesale markets for the aggregation of distributed energy resources. Earlier in the summer, the US Court of Appeals for the DC...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Clark Hill PLC

Landmark FERC Order Opens Door for Wider Participation of Distributed Energy Resources in Wholesale Power Markets

Clark Hill PLC on

On September 17, 2020, the Federal Energy Regulatory Commission (“FERC”) issued Order No. 2222: Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and...more

King & Spalding

Significant Changes to FERC’s Rules for Market-Based Rate Sellers

King & Spalding on

On July 18, 2019, the Federal Energy Regulatory Commission (“FERC”) issued two orders modifying its rules for sellers to obtain or retain authorization to make sales at market-based rates. First, Order No. 861 modifies the...more

Holland & Knight LLP

FERC Seeks Comment on Broad Reforms to Electric Transmission Incentives Policies

Holland & Knight LLP on

On March 21, 2019, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) seeking comment on possibly broad reforms to the scope and implementation of its electric transmission incentives regulations...more

King & Spalding

Hundreds of Parties Submit Comment in Response to Notice of Proposed Rulemaking on Grid Reliability and Resiliency Pricing

King & Spalding on

On September 28, 2017, Secretary of Energy Rick Perry issued a Notice of Proposed Rulemaking (the “NOPR”) directing the Federal Energy Regulatory Commission (“FERC”) “to take action to ensure that the reliability and...more

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