On January 14, 2026, FERC accepted the Southwest Power Pool, Inc.’s (SPP) revisions to its Open Access Transmission Tariff (Tariff) to create a High Impact Large Load (HILL) study process and High Impact Large Load Generation Assessment (HILLGA) process. The HILL study process establishes study and operational requirements for HILLs connecting to SPP’s transmission system. The HILLGA is a new interconnection process for interconnection requests of generation resources necessary to serve HILLs. The Tariff revisions are effective as of January 15, 2026.
ISO-NE Seeks to Establish a Prompt Capacity Market and Deactivation Framework
On December 30, 2025, ISO New England Inc. (ISO-NE) and the New England Power Pool Participants Committee (NEPOOL) filed proposed revisions to ISO-NE’s Transmission, Markets and Services Tariff (Tariff) to establish a prompt capacity market and deactivation framework (CAR-PD) to be implemented starting with the proposed framework’s first annual capacity auction cycle for the June 1, 2028 – May 31, 2029 capacity commitment period (2028/2029 Delivery Period). If accepted, the prompt capacity market will replace ISO-NE’s three-year Forward Capacity Market (FCM). ISO-NE requests that the Commission accept its proposed reforms, effective March 31, 2026.
FERC Orders PJM to Establish Terms and Conditions in its Tariff for Co-Location Arrangements
On December 18, 2025, FERC directed PJM Interconnection, L.L.C. (“PJM”) to revise its Open Access Transmission Tariff (“Tariff”) to:
1) establish terms that an Interconnection Customer seeking to serve co-located load must follow when effectuating a co-location arrangement;
2) clarify the scope and potential of interconnection service when interconnecting new generation to serve co-located load; and
3) require that a customer taking transmission service on behalf of co-located load take one of three new transmission services.
FERC found PJM’s Tariff was unjust and unreasonable because it did not provide the rates, terms, and conditions of service applicable to generators serving co-located load or eligible customers taking transmission service on behalf of such load with sufficient clarity or consistency. FERC separately established a paper hearing to determine just and reasonable rates for new transmission services and ordered PJM to revise the Behind the Meter Generation rules in the PJM Tariff.
FERC Accepts MISO’s Revised Demand Resource Real Power Testing Requirements
On November 17, 2025, FERC accepted the Midcontinent Independent System Operator, Inc.’s (MISO) proposed revisions to its Open Access Transmission Tariff (OATT) to modify real power testing requirements for Demand Resources. MISO specifically proposed more stringent requirements for Demand Resources seeking waiver of performing real power tests and real power tests for Demand Resources using a firm service level baseline. FERC accepted the proposed revisions as just and reasonable, finding the proposed revisions standardize testing procedures for Demand Resources.
FERC Stabilizes Oil Pipeline Price Index Levels for 2021-2026 Period
On November 20, 2025, FERC took several steps aimed at finalizing oil pipeline price index levels for the July 1, 2021, to June 30, 2026, time period (“2021-2026 Period”). First, FERC set the oil pipeline index level for the 2021-2026 Period at PP-FG+0.78% (“Initial Index”), consistent with the index level it originally set in December 2020. FERC also issued remedial relief through a rehearing order to applicable oil pipelines for the March 1, 2022, to September 17, 2024, time period in which an index level of PPI-FG-0.21% (“Rehearing Index”) was in effect. The relief ordered by FERC will allow qualifying pipeline to recover amounts they would have otherwise charged under the Initial Index while the Rehearing Index prices were in effect. Finally, FERC withdrew a Supplemental Notice of Proposed Rulemaking (“Supplemental NOPR”) in which FERC sought to proactively set the Rehearing Index as the index level for the remainder of the 2021-2026 Period.
FERC Staff Audit Report Identifies CIP Standard Compliance Risks in FY2025
On October 20, 2025, FERC Staff issued a report outlining areas of risk to the reliability of the electric grid based on non-public Critical Infrastructure Protection (CIP) Audits of U.S. based North American Electric Reliability (NERC) registered entities’ (Registered Entities) compliance with CIP Reliability Standards during Fiscal Year 2025 (FY2025).
FERC Accepts SPP’s Provisional Load Interconnection Process
On October 10, 2025, FERC accepted Southwest Power Pool, Inc.’s (“SPP”) proposed revisions to its Open Access Transmission Tariff (“OATT”) to establish a provisional load interconnection process. SPP argued the provisional load interconnection process is driven by an increase in requests for load additions and will improve transmission planning and encourage new generation resources to come online by allowing SPP to study interconnection requests while accounting for planned generation. FERC accepted the tariff revisions subject to further compliance, finding the provisional load interconnection process will allow SPP to better understand the impacts of load requests and identify necessary network upgrades.
D.C. Circuit Rejects FERC’s Approval of Tennessee Gas’ Two-Tiered Fuel Rate Structure
On September 30, 2025, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) vacated and remanded FERC’s order approving a two-tiered fuel rate structure for Antero Resource Corporation’s (“Antero”) usage of Tennessee Gas Pipeline Company, L.L.C.’s (“Tennessee Gas”) Broad Run Expansion Project (“Expansion Project”). The D.C. Circuit held FERC’s approval of the rate structure was arbitrary and capricious because it required Antero to always pay for the highest fuel rates irrespective of the segment’s actual operations.
FERC Requires New England Transmission Owners to Answer 2023 Annual Update Information Requests
On September 18, 2025, FERC accepted in part and denied in part the Maine Office of Public Advocate’s (“Maine OPA”) request for eight New England Transmission Owners (“Identified NETOs”) to answer information requests as part of the Information Exchange Period within their Formula Rate Protocols (“Protocols”). Three of the Identified NETOs must now answer Maine OPA’s information requests regarding procedures for evaluating the need for asset condition projects; all Identified NETOs must provide information on their respective procedures for ensuring asset condition projects are not placed in service before such projects are needed.
FERC Clears the Way for the California Independent System Operator’s Extended Day-Ahead Market
On August 29, 2025, FERC issued three orders accepting tariff revisions proposed by PacifiCorp and Portland General Electric (“PGE”) to enable both utility’s participation in the California Independent System Operator Corporation’s (“CAISO”) Extended Day-Ahead Market (“EDAM”) and accepting CAISO’s proposed tariff revisions which modify the EDAM’s allocation of congestion revenues. The three orders issued by FERC clear the way for PacifiCorp and PGE, the first two entities to file tariff revisions to participate in the EDAM, to enter the market in 2026.