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On July 2, 2026, the Federal Energy Regulatory Commission (FERC or Commission) denied a waiver request filed by Chestnut Run Energy LLC (Chestnut Run) seeking a one-time limited waiver of certain requirements under PJM Interconnection, L.L.C.’s (PJM) Open Access Transmission Tariff (Tariff) to allow Chestnut Run to implement an equipment change to its proposed combined cycle gas turbine electric generating facility’s (Facility) configuration.  Chestnut Run sought waiver because of availability issues with certain equipment outlined in its interconnection application.  In denying the request, FERC found Chestnut Run did not demonstrate that the requested waiver would not result in undesirable consequences and noted that the requested waiver would undermine the expeditious nature of PJM’s Reliability Resource Initiative (RRI) process.

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.

On May 21, 2026, FERC denied a complaint filed by Gaston Green Acres Solar, LLC (Gaston) and Bethel NC Hwy 11 Solar, LLC (Bethel) (collectively, with Gaston, Complainants) against PJM Interconnection, L.L.C. (PJM) arguing: (1) PJM’s Open Access Transmission Tariff (Tariff) is unjust and unreasonable because it prevented Complainants from withdrawing their generation projects from PJM’s generator interconnection process Transition Cycle No. 1 without penalty, and (2) in the alternative, FERC should order PJM to issue Bethel its own generation interconnection agreement (GIA) if PJM’s Tariff is not deemed to be unjust and unreasonable in this regard. FERC denied the complaint, finding the Complainants did not satisfy their burden under Federal Power Act section 206, failed to identify Tariff provisions requiring the issuance of a GIA for Bethel, and did not demonstrate that PJM violated its Tariff.

On May 19, 2026, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) dismissed Cage Ranch Solar LLC’s and Cage Ranch Solar II, LLC’s (collectively, Cage Ranch) consolidated petitions for review of FERC orders denying Cage Ranch’s complaint and waiver request, which sought to set aside a deadline by which Southwest Power Pool, Inc.’s (SPP) tariff (Tariff) required Cage Ranch to post financial security for network upgrade costs to support its interconnection requests and maintain its queue position.  The DC Circuit dismissed the petitions for failure to demonstrate a concrete injury in fact necessary to establish Article III standing.

On April 28, 2026, FERC accepted PJM Interconnection, L.L.C.’s (PJM) Open Access Transmission Tariff (Tariff) revisions to establish a price cap and floor for all Reliability Pricing Model (RPM) auctions for the 2028/2029 and 2029/2030 Delivery Years, finding that the price cap and floor will allow PJM to signal the need for additional resources while protecting customers from higher prices.

On April 16, 2026, FERC accepted in part and rejected in part PJM Interconnection, L.L.C.’s (PJM) compliance filing proposing changes to PJM’s Open Access Transmission Tariff (Tariff). FERC accepted PJM’s clarification of procedures for using new generating facilities to serve Co-Located Load but rejected revisions to the definition of “Co-Located Load” and PJM’s incorporation of such definition in specific Tariff sections. FERC ordered PJM to submit a further compliance filing by May 18, 2026.

On February 27, 2026, PJM Interconnection, L.L.C. (PJM) filed revisions to its Open Access Transmission Tariff (Tariff) to establish an Expedited Interconnection Track process for Generating Facilities (EIT Process). According to the filing, the proposed EIT Process would enable PJM to consider up to 10 expedited interconnection requests per calendar year for large new or uprated Capacity Resources. PJM requested an effective date of July 31, 2026, for the tariff revisions implementing the proposed EIT Process and requested an order from FERC by May 28, 2026.

On October 31, 2025, FERC granted ISO New England’s (ISO-NE) request for a limited waiver of its Tariff and Billing Policy to refund, approximately $68,000 in Capacity Performance charges to Brookfield White Pine Hydro LLC (Brookfield).  The waiver relates to six five-minute intervals during a June 24, 2025 Capacity Scarcity Condition in which Harris Hydro Station’s Unit 2 (Harris 2) was manually held below its EcoMax[1] because ISO-NE allowed a non-commercial Large Generating Facility to operate on a constrained transmission line, thereby limiting Harris 2’s output and triggering an underperformance assessment.

On August 25, 2025, the Federal Energy Regulatory Commission (“FERC”) granted NextEra Duane Arnold, LLC (“NEDA”) a waiver of certain sections of the Midcontinent Independent System Operator, Inc.’s (“MISO”) tariff to use MISO’s generating facility replacement process for the recommissioning of the Duane Arnold nuclear power facility (“Project”) in Palo, Iowa. The order also extends the Project’s commercial operation date to December 31, 2029.

On July 11, 2025, the D.C. Circuit upheld PJM Interconnection L.L.C.’s (“PJM”) assessment of $12 million in penalties against Energy Harbor, LLC (“Energy Harbor”) for failing to perform when called upon by PJM during a major winter storm in December 2022. The D.C. Circuit held that PJM-approved maintenance at Energy Harbor’s coal-fired generation facility, the W.H. Sammis Plant (“Sammis Plant”), was not the sole cause of the Sammis Plant’s nonperformance, and therefore Energy Harbor was not excepted from penalties under PJM’s Open Access Transmission Tariff (“OATT”).