Managing RTOs Compliance with Order No. 1000

Our nation-leading role in representing Regional Transmission Organizations (RTOs) and electric transmission facility owners gives us a broad and unique perspective on one of the most critical electric regulation issues of today—RTO rules for determining which new high-voltage transmission lines should be built, who should build them, and who should pay for them. The Federal Energy Regulatory Commission’s (FERC) landmark Order No. 1000 made significant changes in this area of regional and interregional transmission planning and cost allocation. Representing two of the nation’s six FERC-regulated RTOs (PJM Interconnection, L.L.C. (PJM) and Southwest Power Pool, Inc. (SPP)), and most of the transmission owners in a third RTO (MISO Transmission Owners), we’ve handled separate proceedings on compliance with, and implementation of, these new rules.

Knowing the industry as well as the law enabled us to successfully prosecute before FERC all three clients’ initial and several subsequent compliance filings, and we continue to advise and facilitate filings regarding additional compliance and implementation issues and obligations. In fact, our representation has been instrumental in two of our clients obtaining significant exceptions to certain requirements of Order No. 1000 that will enable them to more quickly address immediate reliability needs of their respective transmission systems. We also successfully obtained a rehearing by FERC on whether regional transmission planning processes can take into account state and local laws when deciding whether a project is subject to Order No. 1000 requirements, which will facilitate compliance with such laws. Our continued representation includes ongoing counseling regarding Order No. 1000 and process changes, as well as prosecution of federal judicial appeals of various FERC determinations in certain regions.

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