News & Analysis as of

Tariffs Federal Energy Regulatory Commission

Troutman Pepper Locke

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

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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

Troutman Pepper Locke

FERC Accepts SPP’s Revisions to Its Western Energy Imbalance Tariff Incorporating a Reliability-Based Market Hold Settlement...

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On June 20, 2025, FERC approved Southwest Power Pool, Inc.’s (SPP) revisions to its Western Energy Imbalance Service (WEIS) tariff to allow a participating balancing authority to initiate a market hold due to reliability...more

Foley Hoag LLP - Energy & Climate Counsel

Taking Stock of Tariff Volatility Along the Canadian Border

On February 1, 2025, President Trump issued Executive Order 14193, “Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border,” (the “Canada Tariff EO”), rattling Northeastern policymakers and market...more

Troutman Pepper Locke

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

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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

Frost Brown Todd

D.C. Political News Round-Up | May 2025

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In this month’s deep dive, Frost Brown Todd D.C. Partner-in-Charge Jonathan Miller interviews attorney and tariff expert Jan de Beer to discuss how businesses can navigate the United States’ ever-evolving tariff policies....more

Troutman Pepper Locke

FERC Accepts SPP’s Revised High Priority Transmission Study Planning Process

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On May 14, 2025, FERC accepted Southwest Power Pool, Inc.’s (“SPP”) proposed revisions to its Open Access Transmission Tariff (“OATT”) to modify its high priority transmission study planning process. SPP argued these changes...more

Troutman Pepper Locke

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

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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

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights: V 9, Issue 4, April 2025

Welcome to our fourth issue of Currents 2025. We are covering a multitude of issues in this edition, but we want to pass along a couple of announcements first. Again, thank you for reading! The Data Center Boom...more

Troutman Pepper Locke

FERC Accepts SPP’s Tariff Revisions Regarding Distribution of Make-Whole Payments for Self-Committed Resources

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On March 27, 2025, FERC approved Southwest Power Pool, Inc.’s (SPP) tariff revisions to remove the opportunity for resources that self-commit during the Reliability Unit Commitment Process (RUC) to avoid contributing to RUC...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 Denies Complaint Over $23 Million in Network Upgrade Costs

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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

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

Troutman Pepper Locke

FERC Accepts SPP’s Tariff Revisions Incorporating a Mark-to-Auction Mechanism for SPP’s Transmission Congestion Rights Market

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On March 20, 2025, FERC approved Southwest Power Pool, Inc.’s (“SPP”) tariff revisions to incorporate a mark-to-auction collateral requirement for SPP’s Transmission Congestion Rights (“TCR”) market. In doing so, FERC found...more

Orrick, Herrington & Sutcliffe LLP

NYISO and ISO-NE Prepare for Potential Import Tariffs on Electric Energy

On February 28, 2025, the New York Independent System Operator, Inc. (NYISO) and ISO New England, Inc. (ISO-NE) submitted proposed revisions to their respective wholesale market tariffs to the Federal Energy Regulatory...more

Foley Hoag LLP - Energy & Climate Counsel

“Exigent Circumstances:” ISO-NE and the NYISO Scramble to React as an Electricity Trade War Heats Up at the U.S.-Canada Border

U.S. grid operators and policymakers are rushing to prepare for the Trump Administration’s threatened tariffs on imported Canadian electricity and the Canadian reaction, an unprecedented state of affairs disrupting one of the...more

Husch Blackwell LLP

Two Northeast Grid Operators Prepare for Tariffs on Canadian Energy

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On February 1, 2025, President Trump issued an executive order titled Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border (Canadian Tariff Order), which, inter alia, imposed a 10 percent import...more

Perkins Coie

FERC Initiates Proceeding on Co-Location of Power Demand With Generating Facilities, Raising Issues That Will Reverberate Across...

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The Federal Energy Regulatory Commission (FERC) recently issued an order (Co-location Order) finding that the treatment of load that co-locates behind generating facilities’ points of interconnection with the grid in the PJM...more

Troutman Pepper Locke

FERC Institutes Show Cause Proceeding on Co-Location Issues in PJM

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On February 20, 2025, FERC found that the PJM Interconnection, L.L.C. (“PJM”) Open Access Transmission Tariff (“OATT”) appears to be unjust and unreasonable because it does not address with clarity or consistency the rates,...more

Baker Botts L.L.P.

FERC Approves First Enforcement Settlement Involving Power Plant Operations by Bitcoin Mining Company.

Baker Botts L.L.P. on

Bitcoin mining company pays $1.42 million for violating PJM’s tariff in relation to its power plant operations. On January 30, 2025, the Federal Energy Regulatory Commission (“FERC”) approved a settlement agreement...more

Troutman Pepper Locke

FERC Accepts NYISO’s Proposal Regarding their 2025-2029 Demand Curve Reset

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On January 28, 2025, FERC accepted the New York Independent System Operator, Inc.’s (“NYISO”) proposed revisions to its Market Administration and Control Area Services Tariff (“Services Tariff”). The revisions define the...more

Akin Gump Strauss Hauer & Feld LLP

Oil & Gas in 2025: Emerging Trends & Predictions

As we enter 2025 with a new president in the White House and Republicans in control of both the House and the Senate, we can look forward to a significant shift in the landscape for oil & gas transactions. The second Trump...more

Troutman Pepper Locke

FERC Partially Accepts NorthWestern’s Order Nos. 2023 and 2023-A Compliance Filing

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On November 21, 2024, FERC issued an Order partially accepting NorthWestern Energy Corporation’s (“NorthWestern”) compliance filing, effective July 10, 2024. FERC found that NorthWestern’s filing partially complies with the...more

Mayer Brown

FERC Ends Reactive Power Compensation

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On October 17, 2024, the Federal Energy Regulatory Commission (FERC) issued Order No. 904, Compensation for Reactive Power Within the Standard Power Factor Range (the “Final Rule”), determining it unjust and unreasonable for...more

Troutman Pepper Locke

FERC Accepts SPP's Proposed Tariff Revisions Allowing Make-Whole Payments

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On September 19, 2024, FERC approved Southwest Power Pool, Inc.’s (“SPP”) proposed tariff revisions allowing make-whole payments for incremental energy costs for offers affected by the incremental energy offer cost caps...more

Troutman Pepper Locke

FERC Denies CPower’s Complaint Requesting Revisions to PJM’s Tariff Governing Curtailment Service Providers

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On September 19, 2024, the Federal Energy Regulatory Commission (“FERC”) denied Enerwise Global Technologies, LLC’s (“CPower”) complaint against PJM Interconnection, LLC (“PJM”) alleging that PJM’s Open Access Transmission...more

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