On June 18, 2026, the Federal Energy Regulatory Commission (“FERC”) issued six show cause orders under Section 206 of the Federal Power Act (“FPA”) to each of the country’s regional transmission operators (“RTOs”) and independent system organizations (“ISOs”), along with their transmission owners (collectively, the “Show Cause Orders”). FERC issued the Show Cause Orders as an initial response to the Secretary of Energy’s October 2025 letter directing FERC to initiate an Advance Notice of Proposed Rulemaking (“ANOPR”) presenting potential reforms to ensure the timely and orderly interconnection or large loads to the transmission system. The ANOPR docket, Docket No. RM26-4-000, generated more than 3,500 pages of public comments. The Show Cause Orders also come on the heels of a series of FERC’s actions over the past year designed to address large load growth. These actions include a December 2025 FERC order directing PJM Interconnection, L.L.C. (“PJM”) to adopt clear, transparent tariff rules for large energy users located at or near generation facilities, FERC’s January 2026 approval of Southwest Power Pool, Inc.’s (“SPP”) High Impact Large Load and High Impact Large Load Generation Assessment processes, as well as FERC’s June 2026 approval of SPP’s Conditional High Impact Large Load proposal.
Emily Beard
Emily focuses her practice on energy regulatory matters before the Federal Energy Regulatory Commission (FERC). Drawing on years of experience inside FERC’s Office of General Counsel and as legal advisor to two commissioners, Emily offers clients a deep understanding of how complex policy, technical, and legal issues are evaluated and decided within the Commission.
FERC Proposes Increased Cost Limits and Other Changes to Natural Gas Blanket Certificate Program
On May 21, 2026, the Federal Energy Regulatory Commission (FERC) proposed changes to its natural gas blanket certificate regulations to expand the scope and scale of projects that interstate natural gas pipelines may construct without a case-specific authorization order, and to increase the cost limits for such projects. In a companion order issued the same day, FERC extended a previously granted temporary waiver so that projects constructed and placed in service by May 31, 2028 may continue to rely on an increased prior-notice cost limit.
FERC Approves Golden Triangle’s Spindletop Expansion Project, Reaffirms Market-Based Rates
On March 19, 2026, the Federal Energy Regulatory Commission (“FERC”) granted Golden Triangle Storage, LLC (“Golden Triangle”) a certificate of public convenience and necessity under section 7(c) of the Natural Gas Act for its Spindletop Expansion Project (“Spindletop” or “Project”) in Jefferson County, Texas, subject to detailed engineering and environmental conditions. In the same order, FERC reaffirmed Golden Triangle’s authority to charge market-based rates for storage and hub services and granted associated waivers of cost-based accounting and reporting requirements.
PJM Seeks Extension of Price Collar for Capacity Auctions
On February 27, 2026, PJM Interconnection, L.L.C. (“PJM”) filed an amendment to its Open Access Transmission Tariff (“Tariff”) to extend the price cap and price floor for all Reliability Pricing Model (“RPM”) Auctions through the 2028/2029 and 2029/2030 Delivery Years.
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.