-
Legal & Regulatory
Analysis: FERC Denies Hypothetical Capital Structure Incentive for Valley Link Transmission Project
The Federal Energy Regulatory Commission (FERC) on May 13 of this year issued an order addressing the formula rate filings and requests for transmission rate incentives for the Valley Link Transmission Project Portfolio. The project is a $3-billion, 417-mile multi-state transmission initiative spanning Maryland, Virginia, and West Virginia (collectively, Valley Link). While FERC approved several […]
-
Legal & Regulatory
PJM Capacity Market Reforms Shake Up Resource Accreditation, Impose New Offer and Testing Requirements
The Federal Energy Regulatory Commission (FERC), in Docket No. ER24-99-000, recently approved a suite of tariff revisions submitted by PJM intended to “accommodate the energy transition while maintaining resource adequacy.” Although the reforms affect many aspects of PJM’s Reliability Pricing Model (RPM), this commentary highlights: The transition from capacity accreditation using Equivalent Demand Forced Outage […]
-
Commentary
FERC Approves MISO Interconnection Queue Reforms, Rejects Overall Queue Cap
The Federal Energy Regulatory Commission on Jan. 19 approved most of the Midcontinent Independent System Operator’s (MISO) proposed revisions to its Generator Interconnection Procedures (GIP) designed to reduce the submission and negative impacts of speculative interconnection requests. The changes apply prospectively, starting with the DPP-2023 queue cycle, which has not yet entered the Definitive Planning […]
Tagged in: -
Legal & Regulatory
FERC’s Enforcement in Demand Response Case a Lesson for Utilities
For energy consumers that have flexibility to modify their energy use in response to direction from a utility or the relevant transmission operator (i.e., to reduce load by changing or rescheduling what they are doing), selling demand response (DR) can be a lucrative additional revenue stream. Depending on the location, such consumers may have multiple […]
Tagged in: -
Commentary
Beware Unbridled Enthusiasm—Recent FERC Settlements Hold Lessons for Aggregators
In more than one RTO market, aggregators may find themselves in the position of making capacity offers for future delivery periods based on projections of how much aggregated capability they will have available in the future. This presents somewhat of a dilemma, as there are financial incentives to project aggressively. COMMENTARY Capacity revenues may play an […]
-
Commentary
More Than Statistics: Maximizing Value From FERC OE’s Annual Report on Enforcement
Each year, pursuant to the Federal Energy Regulatory Commission’s (FERC or Commission) Revised Policy Statement on Enforcement, FERC’s Office of Enforcement (OE) publishes “annual statistical reports” summarizing its enforcement activities during the preceding fiscal year (FY). Consistent with that directive, OE’s Annual Report on Enforcement (Annual Report) contains a range of statistical information about the […]
Tagged in: -
Legal & Regulatory
FERC: Investors with Utility Board Members are Affiliates
Building on analysis in its February 2021 Public Citizen, Inc. v. Centerpoint Energy, Inc. opinion, the Federal Energy Regulatory Commission (FERC) recently issued decisions in Evergy Kansas, Inc. (Evergy) and Transalta Energy Marketing (U.S.), Inc. (Transalta) analyzing whether investments that were under 10% of outstanding voting shares, but were paired with appointment of directors that […]
Tagged in: