Reliability

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On November 25, 2025, FERC accepted the Midcontinent Independent System Operator, Inc.’s (MISO) proposal to expand the number of interconnection requests MISO may study under its temporary, fast-tracked generator interconnection process. FERC concluded that the proposal will help ensure interconnection customers are able to interconnect to the MISO transmission system in a reliable, efficient, and timely manner.

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).

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”).

On May 9, 2025, fifteen democratic states (“Plaintiff States”) sued the Trump Administration in Washington District Court, claiming that President Trump’s executive order “Declaring a National Energy Emergency” (“Executive Order”) is unlawful. The Plaintiff States argue that the Executive Order commands federal agencies to disregard the law and applicable regulations to fast-track activities that will damage waters, wetlands, endangered species, and the people and wildlife that rely on these resources.

On April 8, 2025, President Donald Trump issued the Strengthening the Reliability and Security of the U.S. Electric Grid executive order aimed at ensuring adequate and reliable electric generation in the U.S., meeting growing electricity demand being driven by technological advancements (e.g., data centers), and addressing the national energy emergency declared on January 20, 2025. The executive order also intends to help ensure that the electrical grid leverages all available power generation resources, with a particular emphasis on secure resources that have redundant fuel supplies to support extended operations.

On July 30, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) issued an opinion vacating and remanding FERC’s order approving Transcontinental Gas Pipe Line Company’s (“Transco”) Regional Energy Access Expansion Project (“Project”) determining that FERC failed to consider environmental consequences and evidence suggesting…

On July 9, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) vacated orders issued by the FERC that required six wholesale power sellers (the “Sellers”) to issue refunds to customers for power sales made above FERC’s “soft” price cap during the 2020 heatwave in California.  The court held that FERC “should have conducted [a] Mobile-Sierra analysis prior to ordering refunds,” and therefore remanded the orders so that FERC could “change its refund analysis for above-cap sales going forward.”

On March 28, 2024, the Midcontinent Independent System Operator, Inc. (“MISO”) submitted a filing to the Federal Energy Regulatory Commission (“FERC”) proposing revisions to its Open Access Transmission, Energy and Operating Reserve Markets Tariff (“Tariff”) to implement a direct loss of load (“DLOL”) based accreditation methodology.  The DLOL methodology will be used to accredit resources for MISO’s annual Planning Resource Auction and to determine a load serving entity’s resource adequacy for each season during the applicable year.  According to MISO, the proposal will better account for how different resources bolster grid reliability during stress periods.  MISO requests that the tariff revisions take effect on September 1, 2024.

On February 15, 2024, FERC approved two new extreme cold weather Reliability Standards EOP-011-4 (Emergency Operations) and TOP-002-5 (Operations Planning).

This approval is the culmination of a joint inquiry and November 2021 report (“Report”) among FERC, the North American Electric Reliability Corporation (“NERC”), and regional entity staff into a February 2021 cold weather reliability event that affected Texas and the South-Central United States, which was the largest controlled firm load shed event in U.S. history.  The Report recommended reliability standard enhancements to improve extreme cold weather operations, preparedness, and coordination.