On December 15, 2016, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) in Docket No. RM17-3-000 regarding fast-start resources operating in markets run by independent system operators (ISOs) and regional transmission organizations (RTOs). Specifically, the NOPR addresses the manner in which ISOs and RTOs should incorporate offers from fast start-resources into their Day Ahead and Real Time energy prices. FERC claims that these efforts are another step to improve price formation in wholesale electricity markets.
Continue Reading FERC Issues Fast-Start Resources NOPR

On July 21, 2016, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) in Docket No. RM16-17-000 to revise regulations regarding the collection of data for analytics and surveillance purposes from market-based rates (MBR) sellers and entities trading virtual products or holding financial transmission rights (Virtual/FTR Participants). FERC also withdrew two earlier NOPRs in Docket Nos. RM15-23-000 and RM16-3-000. FERC indicated that the newly-issued NOPR would address many of the issues in the withdrawn NOPRs.
Continue Reading FERC Issues NOPR on Information Collection, Rescinds Previous Iterations of Rule

The Federal Energy Regulatory Commission (FERC) has issued a Notice of Proposed Rulemaking (NOPR) to revise its pro forma Small Generator Interconnection Agreement (SGIA). The new rule would require small generators (those that are 20 MW or less) to “ride through” through or to stay connected to and synchronized with the transmission system during a system disturbance.
Continue Reading Small Generators May Soon Be Required to “Ride Through” System Disturbances

This updates our September 28, 2015 report on FERC’s NOPR to require “market participants” in RTO and ISO organized electricity markets to obtain a Legal Entity Identifier (LEI), an alpha-numeric identifier issued through the Global LEI System, and to provide information regarding their “Connected Entities” to the RTO/ISO in which they operate.

Our September 28 report contains a detailed description of the NOPR.  To briefly recapitulate, the NOPR defines a market participant as any seller or buyer of services offered in those markets. 
Continue Reading Update on FERC Notice of Proposed Rulemaking (NOPR) Regarding RTO/ISO Collection of Uniform Organized Market Participant Data


FERC’s September 17, 2015 notice of proposed rulemaking (NOPR) in Docket No. RM15-23-000 would impose significant information-gathering requirements on participants in markets operated by Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs). The rule would require each market participant to obtain a Legal Entity Identifier (LEI) and to report its LEI and extensive additional information about itself and its Connected Entities to its RTO/ISO who would submit it to FERC. FERC has designed the information requirement, which applies on a regular ongoing basis and must be updated as facts and circumstances change, to reveal direct as well as indirect, third party links between market participants that could afford the incentive and ability to engage in joint action to manipulate and defraud the markets.
Continue Reading FERC Issues Notice of Proposed Rulemaking (NOPR) Regarding RTO/ISO Collection of Uniform Organized Market Participant Data

On September 17, 2015, FERC issued a notice of proposed rulemaking (NOPR) regarding settlement intervals and shortage pricing in regional transmission organization (RTO) and independent system operator (ISO) real time electricity markets. The NOPR states FERC’s preliminary finding that RTO/ISO real time use of different time intervals for the dispatch (e.g., five minutes) and the settlement (e.g., one hour) of energy and operating reserve transactions is unjust, unreasonable and unlawful. FERC proposes to require that all RTOs/ISOs use the same time interval for the settlement and dispatch of these transactions.
Continue Reading FERC Issues Notice of Proposed Rulemaking Regarding RTO/ISO Pricing Formation

The Federal Energy Regulatory Commission (FERC or Commission) last week released its final rule, Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, 151 FERC ¶ 61,049 (2015) designated as Order No. 809, in docket RM14-2.  In Order No. 809, the Commission took action on the Notice of Proposed Rulemaking (NOPR) where it had proposed changing the start of the gas day and making scheduling and other changes to the natural gas industry.  The Commission in Order No. 809 (1) declined to adopt its NOPR proposal to move the 9 a.m. Central Clock Time (CCT) start of the gas day to 4 a.m. CCT; (2) adopted proposals submitted by the North American Energy Standards Board (NAESB) revising the interstate natural gas nomination timeline and adding an intraday nomination cycle; and (3) adopted a change in its regulations to allow contracting flexibility for natural gas customers through multi-party contracts.
Continue Reading FERC Issues Final Order on Gas Day NOPR

The Federal Energy Regulatory Commission (Commission) is continuing its practice of transitioning from hard-copy paper submissions to electronic filing procedures. In 2000, the Commission started accepting certain electronic filings through its eFiling system.  Later, in 2008, the Commission began the process of accepting tariff filings electronically through its eTariff system. In a Notice of Proposed Rulemaking (NOPR) issued earlier today, the Commission announced proposed changes to its hearing procedures to allow for the electronic filing of hearing exhibits.
Continue Reading FERC Issues Rulemaking Regarding Electronic Filing of Hearing Exhibits

At its meeting on July 17, 2014, FERC took three significant actions.

Physical Security NOPR

First, and most significantly, FERC issued a notice of proposed rulemaking (NOPR) proposing to approve NERC’s proposed Reliability Standard CIP-014-1, which addresses physical security of certain transmission substations that are the most critical to the operation of the Bulk-Power System.  In a blog article we posted last March, we reported that FERC had directed NERC to promulgate new standards related to physical security within 90 days after significant attention to the issue was raised in the press and in Congress earlier in the year.  Reliability Standard CIP-014-1 tracks the directives FERC had set forth in March to establish standards that provided for the identification of the substations most critical to Bulk-Power System reliability, development of risk assessments and security plans for such critical substations, and verification of those assessments and plans.
Continue Reading FERC Issues Notices of Proposed Rulemaking on Physical Security and Protection System Maintenance and a Final Order on Generator and Transmission Relay Loadability

FERC took the unprecedented step of delaying the filing of comments in its March 20 NOPR, proposing changes to the gas pipeline nomination and scheduling timetable (Docket No. RM14-2; http://www.ferc.gov/whats-new/comm-meet/2014/032014/M-1.pdf) to provide the North American Energy Standards Board (NAESB) the opportunity to develop a counterproposal broadly supported by the industry.  The NOPR requires NAESB to submit any counterproposal developed by the industry by September 16, 2014.  NAESB filed a status report with FERC on June 18, 2014.  This post is the second in a series addressing various issues related to gas-electric coordination.
Continue Reading Can NAESB “Fix” FERC’s Gas Scheduling Proposal?