Skip to content

On April 10, 2020, the Federal Energy Regulatory Commission (FERC) issued an order (April Order) on PJM Interconnection, LLC’s (PJM) proposal for minimum run-time requirements for capacity storage resources. The April Order relates to Order No. 841 from December 2018, which opened energy markets to energy storage, and a FERC order from October 2019, where PJM obtained FERC’s green light to implement its energy storage proposals in compliance with Order No. 841, but also instituted an investigation under section 206 of the Federal Power Act to examine whether PJM’s proposed minimum run-time requirements for capacity storage resources are unjust, unreasonable, or unduly discriminatory as applied to capacity storage resources. In the same proceeding, FERC directed PJM to submit tariff provisions reflecting its minimum run-time rules applicable to all resources. These developments are covered in the prior GT Alert, “Thumbs Up for Energy Storage: FERC Approves PJM and SPP Proposals Implementing Order No. 841.”

Read the full GT Alert here.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Gregory K. Lawrence Gregory K. Lawrence

Gregory K. Lawrence focuses his practice on the electricity and natural gas industries. He is experienced appearing before the Federal Energy Regulatory Commission (FERC) and multiple state utility commissions regarding regulatory proceedings, compliance and enforcement, capacity and energy market structure, transactions and negotiations,

Gregory K. Lawrence focuses his practice on the electricity and natural gas industries. He is experienced appearing before the Federal Energy Regulatory Commission (FERC) and multiple state utility commissions regarding regulatory proceedings, compliance and enforcement, capacity and energy market structure, transactions and negotiations, asset transfers, and governmental affairs. Greg’s clients include funds and financial institutions, marketers, traders, renewable and other project developers, energy storage and demand response assets, municipal and investor-owned utilities, and large energy consumers.

Recognized as a leading energy and electricity lawyer by Chambers USA, Greg is a frequent speaker at energy industry conferences and a contributor to a wide range of publications, including The Electricity Journal, Electric Light & Power, Energy Risk, Bloomberg Law Reports, Project Finance International, Corporate Counsel, Windpower Engineering, and EnergyLaw 360. He also authored a quarterly column in Electric Energy T&D Magazine and “Rationalizing Supply with Demand: Electricity Demand Response in U.S. Wholesale Electricity Markets,” a book chapter in U.S. Law and Taxation.

Photo of Thomas O. Lemon Thomas O. Lemon

Thomas O. Lemon focuses his practice on litigation and regulation in the energy sector. After receiving his J.D. from Washington University in St. Louis in 2011, Tom worked as an attorney-advisor in the Federal Energy Regulatory Commission’s (FERC) Office of Enforcement. In his

Thomas O. Lemon focuses his practice on litigation and regulation in the energy sector. After receiving his J.D. from Washington University in St. Louis in 2011, Tom worked as an attorney-advisor in the Federal Energy Regulatory Commission’s (FERC) Office of Enforcement. In his time at the Commission, Tom worked on nearly every type of FERC Enforcement matter, and has extensive experience with natural gas and electricity market fraud and manipulation claims, NERC reliability standards violations, wholesale demand response, and LMP and capacity price formation. He has done investigatory and enforcement work in several ISO and RTO markets, including CAISO, PJM, NYISO, and ISO New England.