On April 21, 2022, the Federal Energy Regulatory Commission (“FERC”) issued an Order directing six Regional Transmission Organizations and Independent System Operators (“RTO/ISO”) to submit reports to the Commission providing information on their changing system needs and plans for potential reforms. 

During the fall of 2021, the Commission held two technical conferences to discuss the operational challenges RTOs/ISOs face, such as the changing resource mix, changes in customer electric loads, and potential reforms that RTOs/ISOs are pursuing to provide for greater operational flexibility in energy and ancillary service markets.  Following the conferences, FERC sought comments from interested parties on the topics discussed at the conferences, which were due to the Commission in early 2022.  The discussions at the technical conferences and the comments the Commission received revealed that developing a “one-size-fits-all” solution to RTO’s/ISO’s changing system needs presents significant challenges.  As a result, the Commission has issued an Order to gather additional information to enhance its understanding on the changing system needs in each RTO/ISO, and potential mechanisms and reforms for addressing those needs.

Specifically, the Commission’s Order seeks information on the following topics:  (1) the current system needs that each RTO/ISO faces; (2) the changing system needs that each RTO/ISO expects to face over the next five and ten years; (3) any energy and ancillary service market reforms that the RTO/ISO plans to propose and how the RTO/ISO expects those reforms will meet the expected changing system needs over the next five and ten years; and (4) potential reforms that may be needed beyond energy and ancillary service market reforms to meet the expected changing system needs. 

The Commission’s proceeding on this matter is Modernizing Wholesale Electricity Market Design (Docket No. AD21-10).  The RTO/ISO reports are due within 180 days of the issuance of the Commission’s Order.  Interested parties may submit comments within 60 days of the RTO/ISO filing its report.

For more information, please contact Michael Postar, Lisa Gast, Sean Neal or Gelane Diamond.