October 22, 2025

Regulatory Update for October 22, 2025

(Covering October 15-21, 2025)

Our energy regulatory team has compiled a list of state and federal energy regulatory developments to keep you up to speed on key energy regulatory matters from across the United States. Stoel’s energy regulatory team is always available to answer questions about any of these developments. Click here to meet the energy regulatory team.

Jump to the following jurisdictions:

State Regulatory Agencies

• California Public Utilities Commission (CPUC)
• California Energy Commission (CEC)
• California Air Resources Board (CARB)
• Minnesota Public Utilities Commission (MPUC)
• Oregon Public Utilities Commission (OPUC)
• Washington Utilities and Transportation Commission (WTUC)

Federal Regulatory Agencies

• Federal Energy Regulatory Commission (FERC)

Independent System Operators (ISO) and Regional Transmission Organizations (RTO)

• California Independent System Operator (CAISO)
• ISO-New England (ISO-NE)
• PJM Interconnection (PJM)
• New York Independent System Operator (NYISO)
• Midcontinent Independent System Operator (MISO)

Click here to download this update as a PDF

State Regulatory Agencies

CALIFORNIA PUBLIC UTILITIES COMMISSION (CPUC or COMMISSION)[1]

Proposed Decisions and Resolutions

Rulemaking (R.) 22-11-013 (Order Instituting Rulemaking to Consider Distributed Energy Resource Program Cost-Effectiveness Issues, Data Access and Use, and Equipment Performance Standards)

This decision revises the biennial process for the upcoming and future Avoided Cost Calculator (ACC) updates. The ACC calculates seven types of avoided costs: generation capacity, energy, transmission and distribution capacity, ancillary services, Renewables Portfolio Standard, greenhouse gas emissions, and high global warming potential gases. The CPUC uses the ACC to determine the primary benefits of distributed energy resources across Commission proceedings. The decision also increases the budget for consultant costs of the ACC biennial updates from $350,000 to $1,200,000 per year.

Application (A.) 23-07-008 (In the Matter of the Application of California Resources Production Corporation for a Certificate of Public Convenience and Necessity to Operate as a Gas Corporation in the State of California)

This decision denies Application 23-07-008, in addition to denying the request to hold this proceeding in abeyance made by the cities of Antioch and Brentwood, California. The decision further denies California Resources Production Corporation’s motion to amend Application 23-07-008,and grants for a period of three years California Resources Production Corporation’s motions to file certain materials as confidential under seal.

Resolution (Res) E-5428

This Resolution approves eight contracts across three projects, for Southern California Edison (SCE), two of which are mid-term reliability (MTR) co-located battery energy storage and solar photovoltaic (PV) projects, while one of the projects is a solar PV project. All eight of these contracts were entered into as a result of Phases 2 and 3 of SCE’s Mid-Term Reliability Request for Offers (MTRRFO). Additionally, this Resolution approves an amendment to one previously Commission-approved battery energy storage system (BESS) contract with Gateway Energy Storage, LLC for portions of the Gateway project that was executed as part of Phase 1 of SCE’s MTRRFO and approved by CPUC Resolution E-5205 in May 2022. SCE contracted these nine different resources to help meet its MTR requirements.

Rulemaking (R.) 18-04-018 (Order Instituting Rulemaking to Evaluate the Mobilehome Park Pilot Program and to Adopt Programmatic Modifications)

This decision directs Pacific Gas & Electric, SCE, and San Diego Gas & Electric to work with the California Energy Commission’s (CEC) Equitable Building Decarbonization program staff and administrators to fully electrify select mobilehome parks across the state, as part of a joint CPUC and CEC mobilehome electrification pilot initiative. Through the pilot initiative, selected mobilehome parks (MHPs) will also be enrolled in the Commission’s existing Mobilehome Park Utility Conversion Program (MHP UCP) to have their submetered electrical systems converted to direct-metered, utility-owned systems. The Commission reasons that the purpose of this joint electrification pilot initiative is to better understand technical, legal, and policy concerns related to full mobilehome park electrification and to inform potential changes to the MHP UCP in the future.

Voting Meeting

The CPUC will hold a voting meeting in Sacramento, California on October 30, 2025, at 11:00 a.m. PT.  The energy-related items on the agenda are below:

Item 3.  Res G-3606 (San Diego Gas & Electric Company (SDG&E) 2024 Natural Gas Leak Abatement Ratemaking Forecasts and Capital Costs Recovery)

This Resolution denies SDG&E’s 2024 Natural Gas Leak Abatement (NGLA) ratemaking forecasts as presented in Advice Letter (AL) 3285-G-A for costs for its 2024 Compliance Plan.  SDG&E forecasts a total revenue requirement of $24.859 million in AL 3285-G-A: $22.919 million for Best Practices; $1.29 million for Research, Development, and Demonstration (RD&D) projects; $0.428 million for Program Administration; and $0.222 million for any under-recovered ongoing capital revenue requirements.  This Resolution approves no funding for Best Practices because none of the practices is cost-effective.  Costs for RD&D are also denied.  SDG&E is authorized to record up to $0.428 million for NGLA Program Administration, if applicable, in the NGLA Program Memorandum Account for potential recovery in a future general rate case (GRC) or other proceeding, where it will be subject to a reasonableness review.  The Resolution approves $222,000 for unrecovered ongoing capital costs from previously approved Compliance Plans. 

Item 4.  Rulemaking (R.) 20-05-012 (Order Instituting Rulemaking Regarding Policies, Procedures and Rules for the Self-Generation Incentive Program and Related Issues)

This decision establishes the conditions for returning ratepayer funds and closing out all activities related to the ratepayer-funded portion of the Self-Generation Incentive Program (SGIP).  The decision also implements the Greenhouse Gas Reduction Fund portion of SGIP as well as conditions for its closure in 2028.  Also included in this decision are modifications to existing rules for extending SGIP projects and participation in a qualifying demand response program for SGIP’s Residential Solar and Storage Equity budget. 

Item 5. Application (A.) 25-04-015 (Application of San Diego Gas & Electric Company for Authority to Establish a Ratemaking Mechanism for Energization Projects Pursuant to Senate Bill 410)

This decision authorizes SDG&E to establish a new Electric Energization Memorandum Account (EEMA) to record energization costs that are incremental to the energization costs approved in SDG&E’s 2024 GRC. SDG&E is authorized to record a total of $51.188 million of incremental costs to the EEMA: $10.561 million in 2024, $20.793 million in 2025, and $19.834 million in 2026. This represents an 83 percent reduction of SDG&E’s requested cap of $310.127 million from 2024 to 2026. SDG&E’s initial request would have more than doubled the amount of money it is authorized to spend on energization-related projects by its 2024 GRC; this decision authorizes no more than an 18 percent increase. SDG&E is authorized to annually transfer eligible costs to the Electric Distribution Fixed Cost Account for recovery from customers. The decision provides guidance for SDG&E to request revisions to the cap via petition for modification. Through this decision, SDG&E is authorized, on an annual basis, to begin recovering eligible costs recorded to the EEMA from customers.

Item 7. Rulemaking (R.) 18-07-003 (Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program)

This decision denies the March 6, 2025, petition to modify Decision (D.) 20-08-043, filed by the Bioenergy Association of California (BAC). BAC is seeking to extend or remove the end date of the Bioenergy Market Adjusting Tariff (BioMAT) and proposing other programmatic changes, primarily due to underutilization of this high-cost program and availability of other procurement options for bioenergy resources. The Commission reasons that maintaining the BioMAT end date, December 31, 2025, as directed by the Commission in D.20-08-043, is in alignment with October 30, 2024, Governor’s Executive Order N-5-24 on affordability, and will allow Commission resources to be directed toward more effective clean energy programs.

Item 9. Resolution (Res) E-5426

This Resolution establishes the IRP Filing Citation Program (IRP FCP). The IRP FCP will apply to all Load Serving Entities subject to the Commission’s oversight in an IRP Proceeding. Commission Staff will be delegated authority to issue citations and levy fines for failure to comply with any mandatory filing deadlines and reporting requirements in IRP Proceedings, including the planning and procurement tracks. The penalty amounts set forth in Appendix A are final and not subject to modification on appeal. Nothing in this Resolution diminishes, alters, or reduces the Commission’s existing authority to implement and administer the IRP program.

Item 10. Application (A.) 24-08-013 (Application of Pacific Gas and Electric Company for a Determination Under Section 851 of Whether a Condemnation of Assets by the South San Joaquin Irrigation District Would Serve the Public Interest)

This decision dismisses, without prejudice, Pacific Gas and Electric Company’s (PG&E) Application to determine whether, under Section 851, a condemnation of assets by the South San Joaquin Irrigation District (SSJID) would serve the public interest. After PG&E and the SSJID have concluded their eminent domain action currently pending before the San Joaquin Superior Court, PG&E will file an application, consistent with Public Utilities Code Section 851, et seq., for Commission review, and at that time the Commission will determine the appropriate scope of its review.

Item 12. Resolution (Res) E-5420

This Resolution approves, with modification, PG&E’s AL 7569-E, which requests Commission approval of two agreements to support the energization of a new 90-megawatt data center load in San Jose, as requested by STACK Infrastructure. These agreements facilitate the construction of new transmission facilities to serve STACK’s load. The Commission approves the AL with modifications, finding the agreements necessary and largely appropriate to energize this new load.

Petition (P.) 21-07-012 (Petition of the City and County of San Francisco for a Valuation of Certain Pacific Gas & Electric Company Property Pursuant to Public Utilities Code Sections 1401-1421)

This decision adopts standards of just compensation that are applicable in this proceeding. The decision adopts the following principles of just compensation: (a) PG&E’s shareholders and remaining customers are made whole; (b) the City and County of San Francisco’s condemnation of PG&E’s property in and around San Francisco constitutes a partial taking; and (c) PG&E may be entitled to business and physical severance damages.

Item 16. Resolution (Res) E-5419

This Resolution approves two swap contracts for bundled portfolio content category 1 (PCC-1) renewable energy credits (RECs) and energy. SCE is seeking approval to count its purchase contract for June 1, 2025, through May 31, 2026, executed as part of the swap as a bridge toward the energy portion of SCE’s Diablo Canyon Replacement procurement requirement under Ordering Paragraph of D.21-06-035.

Item 21. Application (A.) 24-05-002 (Application of West Coast Gas Company to Revise its Gas Rates and Tariffs)

This decision grants the Joint Motion for Adoption of the Amended Settlement Agreement (Amended Settlement Agreement) between West Coast Gas Company, Inc., and the Public Advocates Office. The Amended Settlement Agreement results in an increase in Base Rate Revenue of $96,358.46 and total 2025 Test Year Revenue of $1,475,538.94 and resolves all issues in this GRC proceeding.

Item 25. Application (A.) 24-05-004 (Application of Pacific Gas and Electric Company for Approval of Natural Gas Curtailment Procedures Pursuant to Decision 23-11-069)

Decision 23-11-069, issued in PG&E’s 2023 GRC Proceeding, directed the utility to file Application 24-05-004, to revise the curtailment procedures in its Gas Tariff and make the revised procedures “similar to” the curtailment procedures of other large energy utilities. The purpose of the Commission’s directive and the aim of the utility’s application are to expand the utility’s curtailment tools by adding tariff provisions for systemwide curtailment procedures similar to what other large California energy companies use. According to the Commission, the utility currently relies on localized curtailment procedures. This decision corrects that situation by approving the addition of specific systemwide curtailment procedures to PG&E’s existing curtailment procedures.

Upcoming Workshops and Events

Transportation Electrification Proactive Planning Webinar

The CPUC will host a webinar on October 22, 2025, to host a technical workshop and take stakeholder feedback regarding the Energy Division’s Transportation Electrification Proactive Planning (TEPP) efforts.  As outlined in the Scoping Memo for R.23-12-008, TEPP is focused on zero-emission vehicle planning related to corridor freight charging infrastructure and similar loads such as light-duty charging plazas.  This proceeding is focused on improving transportation electrification-specific data, assumptions, and analyses that can ultimately be inputs into existing electric grid planning processes (e.g., Distribution Planning Process, Transmission Planning Process, etc.) that are being developed in other proceedings.  A ruling issued on October 1, 2025 requests stakeholder comments on the inputs and assumptions for TEPP modeling and related information.  Comments in response to the ruling are due October 31, 2025, and reply comments may be submitted by November 14, 2025.

Webinar on Clean Energy Permitting Playbook

The CPUC issued a webinar notice to several procurement and planning proceedings of an upcoming webinar to discuss initiatives to support local jurisdictions’ permitting of clean energy projects.  The webinar, which will be held on October 22, from 12:00 p.m.to 1:30 p.m. PT, will provide an overview of the near final version of the Clean Energy Permitting Playbook and Toolkit (explanation of the structure, highlighting key components, and showcasing select tools) and outline next steps for feedback and continued collaboration.  Additional information and registration details are available here. 

CALIFORNIA ENERGY COMMISSION (CEC)

2025 Integrated Energy Policy Report (IEPR)

The CEC has released the 2025 IEPR workshop schedule and opened a new proceeding number (25-IEPR-01) for the 2025 IEPR.  Workshop topics and dates included in the notice are below (note: the workshop schedule is subject to change, and the current schedule was released on July 2, 2025).  Upcoming workshops or comment deadlines and recent changes to the workshop schedule are reflected below:

• November 13, 2025: IEPR Commissioner Workshop on Load Modifier Results (remote access only).
• December 11, 2025: IEPR Commissioner Workshop on Forecast (remote access only) – rescheduled from December 2, 2025.

On October 8, 2025, the CEC circulated a “Save the Date” email regarding a Demand Analysis Working Group (DAWG) meeting scheduled for 1:30 p.m. PT on October 30, 2025.  According to the DAWG meeting website, the meeting will be held both remotely and in-person, and will focus on the California Energy Demand Forecast for the draft load modifier results for the 2025 IEPR.  Specifically, the meeting will address the following topics:

• Behind the meter photovoltaics and storage
• Additional Achievable Transportation Electrification
• Additional Achievable Energy Efficiency and Fuel Substitution
• Data centers
• Utility “Known Loads” project data used for distribution system planning
• Improvements to the methodology to calibrate sector end use model results with historical data

On July 22, 2025, the CEC released a Revised Scoping Order for the 2025 IEPR, which updates the original Scoping Order posted in March 2025.

Renewables Portfolio Standard 10th Edition Guidebook Update

On September 18, 2025, the CEC released the draft Renewables Portfolio Standard Guidebook, Tenth Edition (Guidebook) for public review and comment.  CEC Staff held a remote access workshop to discuss the draft Guidebook on October 6, 2025.  Written comments on the Guidebook were due to Docket 21-RPS-02 by October 20, 2025. 

Funding for Electric Vehicle (EV) Charging

The CEC is accepting funding applications under the Fast Charge California Project, which includes up to $55 million of in-state funding for up to 100 of the installation costs for EV chargers at businesses and public sites across the state, through October 29, 2025.  Funding priority will be given to tribal areas and low-income and underserved communities.  Eligibility details and other application requirements are available here.

Proposed Amendments to Regulatory Definitions Appurtenant and Related Facilities

On October 9, 2025, CEC staff held a workshop to gather feedback from interested parties regarding the addition of the definition of “appurtenant facility” and proposed amendments to the CEC’s definition of “related facility” as contained in Title 20, California Code of Regulations.  Proposed regulatory amendment language is included in the workshop notice.  Written comments may be submitted in hard copy to the CEC or via email by October 24, 2025.  According to the workshop notice, written comments should reference Docket Number 25-RULE-01 in the subject line and should be emailed to docket@energy.ca.gov.

Clean Transportation Program Investment Plan

On October 27, 2025 at 11:00 a.m. PT, the CEC will host a hybrid meeting of the Advisory Committee for the Clean Transportation Program Investment Plan to discuss the staff draft report version of the 2025–2026 Investment Plan Update for the Clean Transportation Program, including proposed funding allocations.  According to the meeting notice, Commissioner Nancy Skinner, Presiding Member of the Advisory Committee, will attend the October 27, 2025 meeting.  Written comments are due to the Docket Unit by 5:00 p.m. PT on November 7, 2025, under Docket No. 25-ALT-01.

Demand Side Grid Support (DSGS) Program

The CEC hosted a workshop on October 15, 2025 to present staff’s analysis of the DSGS Program during the 2024 season, with a focus on the Storage Virtual Power Plant performance, which is also referred to as Incentive Option 3.  Additional information is available on the event page, here.

Pursuant to a notice issued by the CEC on October 1, the DSGS Program has budgeted funding of $109.5 million, as of the Budget Act of 2025.  From that amount, about $64 million remains after accounting for incentives for past program seasons (including the 2024 season), encumbrances (third-party contracts through 2028), and program administration expenses through the end of the 2024–25 Fiscal Year.  Program staff anticipate having sufficient funding for the 2025 program season incentive payout and continuation of the DSGS Program for the 2026 program season with modifications, to align with the funding level projected to be available after the 2025 incentive payout.  Workshops will be announced at later dates to present staff’s analysis of DSGS Program performance in the 2024 program season and present potential changes to the DSGS Program for the 2026 program season.

Gas Research and Development Program

On October 13, 2025, CEC staff hosted a remote access scoping workshop regarding staff’s proposed concept for funding research to advance integrated planning to support gas system decommissioning.  According to the workshop notice, “the workshop will conclude with a question-and-answer session and public comment period to advance integrated planning to support gas system decommissioning.”  Written comments were due to the Docket Unit for Docket No. 23-ERDD-02 by October 20, 2025.

CEC Business Meetings

The next CEC Business Meeting is scheduled for November 12, 2025.  

CALIFORNIA AIR RESOURCES BOARD (CARB)

Climate Risk Disclosure Laws Update

Although CARB originally announced it would issue proposed rules for the state’s climate risk disclosure laws, Senate Bills (SB) 253 and 261, on October 14, 2025, CARB released an update that it will be delaying the rulemaking until Q1 2026 due to “the large volume of public comments staff have received, and given ongoing input related to identifying the range of covered entities.”  CARB also issued a projected cost of compliance for the laws and shared the disclosure timeline for companies covered by SB 253 to disclose their scope 1 and scope 2 emissions for the first time.  Companies covered by SB 253 should expect to report their scope 1 and scope 2 emissions by June 30, 2026.

Meetings and Workshops

On October 29, 2025, CARB will hold a public workshop on updates to the California Cap-and-Invest Program (formerly Cap-and-Trade). CARB staff will provide an overview of recently signed legislation, Assembly Bill 1207 (AB 1207, Irwin, statutes of 2025) and Senate Bill 840 (SB 840, Limón, statutes of 2025), that provides direction on the Cap-and-Invest Program and discuss related potential updates to the Cap-and-Trade Regulation.

On October 30, 2025, CARB will hold a public meeting as part of CARB’s ongoing rulemaking process on embodied carbon. The purpose of this technical meeting is to receive feedback from interested parties and potentially regulated entities on staff concepts for an embodied carbon reporting regulation. At this meeting, CARB staff will present information on the technical work being done to develop an embodied carbon reporting regulation pursuant to Assembly Bill (AB) 2446 (Holden, 2022) and AB 43 (Holden, 2023), and to request feedback from interested parties who may have expertise in manufacturing, importing, or retailing of building materials, as well as those with expertise on planning, developing, designing, and constructing new buildings.

On November 6, 2025, CARB will conduct a joint public meeting between CARB, the California Transportation Commission, and the California Department of Housing and Community Development, to coordinate their implementation of policies that jointly affect transportation, housing, and air quality, including interagency efforts.  Presentations will facilitate open dialogue amongst state agencies and the public.

On November 20, 2025, CARB will conduct a public hearing to consider approving for adoption the proposed amendments to the Regulation on Methane Emissions from Municipal Solid Waste Landfills (LMR).  CARB adopted the LMR in 2010 to reduce methane emissions from municipal solid waste landfills, which are the second-largest source of methane emissions in California.  The LMR requires owners and operators to install and optimally operate landfill gas collection and control systems to minimize emissions, monitor surface methane concentration and other performance parameters, repair emission exceedances and other performance issues, conduct source testing of combustion devices used to destroy methane, and report compliance information to CARB and local air districts.

MINNESOTA PUBLIC UTILITIES COMMISSION (MPUC)

At its October 23, 2025, weekly agenda meeting, the MPUC will consider (1) Northern States Power Company (Xcel) and Owatonna Public Utilities’ joint request for approval of a permanent boundary change from Xcel to Owatonna Public Utilities (Docket No. E002, E290-SA-25-315); (2) approval of Minnesota Power’s 2024 remaining life depreciation proposal, and its proposal for Track and Defer Costs resulting from the Legacy Coal Combustion Surface Impoundment Rule (Docket Nos. E015/D-24-324; E015/M-24-437); (3) acceptance of Great Plains Natural Gas Co.’s (Great Plains) Annual Report and Petition for Approval of Recovery for Gas Utility Infrastructure Costs and Revised Adjustment Factors for 2025 (Docket No. G004/M-25-200); (4) approval of Great Plains’ annual depreciation certification (Docket No. G004/M-25-243); and (5) whether Minnesota’s electric utilities have provided adequate information in the March 2024 and March 2025 compliance filings on self-commitment, or should be required to provide additional information or take additional steps regarding self-commitment at this time, and whether to modify the filing requirements for future years. (Docket No. E999/CI-19-704).  

OREGON PUBLIC UTILITIES COMMISSION (OPUC) & WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION (WUTC)

At its October 28, 2025, public meeting, the OPUC will hold a hearing and commissioner work session related to PGE’s 2024 Distribution System Plan, which describes PGE’s strategy for modernizing and building out a cost-effective clean energy grid that supports affordability, electrification, and decarbonization (Docket No. UM 2362). PGE’s Distribution System Plan is accessible here. Additionally, on October 28, the OPUC will hold a special public meeting regarding the Purchase Gas Adjustment. The OPUC will also hold a special public meeting regarding its investigation into guidelines for wildfire mitigation plans (WMPs), particularly phase 2 of those guidelines, which will be led by PGE, Pacific Power, and Idaho Power and involve creation of a glossary of shared terminology to be used in all WMPs and a standard format for multi-year WMPs (Docket No. UM 2340).

The WUTC will meet October 23, 2025, to discuss Avista Corporation’s revisions to its Tariff WN U-29, Schedule 162 and Schedule 163, Climate Commitment Act, which will decrease revenues by $7.6 million, or 2.7 percent. The monthly bill for an average residential ratepayer with gas service connected prior to July 1, 2021, will decrease $3.18, or 3.3 percent (Docket No. UG-250663). Additionally, on October 27, 2025, the WUTC will hear an introduction to the Bonneville Power Administration’s Grid Access Transformation Program (UE-000000), and on October 30, 2025, the WUTC will hear a presentation from the California Water Service Company on Promise to Pay and Polyfluoroalkyl Substances (PFAS) (Docket No. UW-230645).

Federal Agencies

FEDERAL ENERGY REGULATORY COMMISSION (FERC)

Orders   

FERC rejected a waiver from Nevada Power Company and Sierra Pacific Power Company that would have allowed any interconnection customer with an effective Large Interconnection Agreement (LGIA) or pending interconnection request that has paid a deposit to withdraw its request or terminate its LGIA and receive its deposit back and not have to pay a withdrawal penalty. FERC noted the waiver would establish a safe harbor process not included in the tariff.   

FERC issued orders accepting compliance filings from MISO, SPP, and ISO-NE related to Order 904, addressing the elimination of reactive power compensation within generator interconnection agreements.

Meetings and Conferences

FERC held its October Commission Meeting on October 16, 2025. Among other orders, FERC:

• denied a complaint regarding PJM’s practices related to long-term firm point-to-point transmission;
• addressed exceptions to definitions for Upgrades and Direct Assignment Facilities under PG&E’s third Wholesale Distribution Tariff; and
• issued a notice of proposed rulemaking to amend FERC regulations to incorporate revisions related to Standards for Business Practices of Interstate Natural Gas Pipelines.

A full list of FERC orders issued during its October 16 meeting may be found here.

On October 21, 2025, FERC held a technical conference to discuss cost-effective ways to reduce the risk of wildfire ignition from the bulk power system, as well as its Reliability Technical Conference to discuss policy issues related to the reliability and security of the Bulk-Power System. 

FERC noticed its fourth public meeting of the Federal and State Current Issues Collaborative on cross-jurisdictional issues relevant to FERC and state utility commissions, which will take place on November 12, 2025.  The meeting will explore topics related to energy infrastructure permitting, and FERC will release an agenda for the meeting by October 29, 2025.  The meeting will take place in Seattle, Washington and over Webcast.

Reports

FERC published a staff report titled Lessons Learned from Commission-Led CIP Reliability Audits, noting that FERC staff completed non-public Critical Infrastructure Protection Audits, which found that, although most entities evaluated met the mandatory reliability requirements, “potential noncompliance and security risks remained.”

Independent System Operators (ISO) and Regional Transmission Operators (RTO)

CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)

Stakeholder Initiatives: Upcoming Meetings and Deadlines

Interconnection Process Enhancements 5.0.  CAISO posted the draft final proposal for the Interconnection Process Enhancements 5.0 initiative. Written comments are due November 3, 2025.  Further information is available here.

Cluster 15 Cluster Study Reports.  Cluster 15 Cluster Study Reports are expected to be published October 29, 2025, and will be available in the Grid Resource Interconnection Portal.  The user guide has been updated to provide instructions to view the report and provide next steps.  Further information is available here.

Western Energy Markets Regional Issues Forum.  The Western Energy Markets Regional Issues Forum has announced its upcoming hybrid meeting and posted the final agenda. The meeting will take place at the CAISO in Folsom, California on October 27, 2025.  Registration is requested for in-person attendees by October 23, 2025. Additional information is available here.

Intertie Scheduling and Resource Adequacy Imports in Extended Day-Ahead Market Workshops.  CAISO will host a two-day hybrid stakeholder call on November 5, 2025, and November 6, 2025, to discuss key elements of EDAM Implementation. Further information is available here.

Day-Ahead Market Enhancements (DAME), Extended Day-Ahead Market (EDAM) and EDAM CAISO Balancing Authority Participation Rules.  CAISO will offer on November 10, 2025, a continuation of the settlements-focused training session tailored for Scheduling Coordinators involved in, or impacted by, the upcoming Spring 2026 launches of DAME, EDAM, and EDAM ISO Balancing Authority Area Participation Rules.  Further information is available here.

ISO-NEW ENGLAND (ISO-NE)

Transitional Cluster Study

ISO-NE has begun its first Transitional Cluster Study, which it developed in response to FERC Orders 2023 and 2023-A, to address interconnection queue backlogs. ISO-NE has stated that 26 interconnection requests have qualified to be included in the study, including 21 battery energy storage projects, two solar photovoltaic projects, and three wind projects. ISO-NE projects that the Transitional Cluster Study will be completed by August 6, 2026.

Meeting

ISO-NE noticed an open meeting on November 5, 2025, from 1:00 to 4:30 p.m. ET held by the ISO’s board of directors, which will discuss ISO-NE’s 2025 draft Regional System Plan. The meeting will take place at the Hilton Boston Logan Airport Hotel and virtually. Advance registration is required to attend in person. No advance registration is required for virtual attendance.

PJM INTERCONNECTION (PJM)

Revisions to PJM Operating Agreement and Reliability and Assurance Agreement Members

FERC accepted revisions to PJM’s Amended and Restated Operating Agreement and Reliability and Assurance Agreement among Load Serving Entities to reflect updated member lists. A list of the updated members may be found here.

Meeting

PJM will hold its Markets and Reliability Committee and Members Committee meetings on October 23, 2025. PJM is projected to discuss the following issues:

• Proposed Revisions to Manual 3A: Energy Management System Model Updates and Quality Assurance;
• Dispatches of renewable resources in the real-time energy market;
• Offer capping of resources scheduled in advance of the day-ahead energy market;
• Revisions to Manual 14D: Generation Operational Requirements;
• Resource scheduling prior to day-ahead energy market; and
• Revisions to allow demand response resources to offer regulation-only services.

NEW YORK INDEPENDENT SYSTEM OPERATOR (NYISO)

Order 2023 Compliance Filing

FERC partially accepted NYISO’s compliance filing submitted in response to FERC Order Nos. 2023 and 2023-A, which govern interconnection procedures. FERC had previously directed NYISO to submit further compliance filings after NYISO’s initial Order 2023 compliance filings with respect to issues relating to cluster studies and co-located generating facilities, among other issues. In its Order, FERC accepted NYISO’s proposed revisions related to cluster studies and co-located generating facilities, including independent entity variations, but rejected NYISO’s revisions to remove five categories of Expedited Deliverability Study revisions and ordered NYISO to file a further compliance filing on this issue.

Comprehensive Reliability Plan

NYISO’s Operating Committee voted to approved NYISO’s draft Comprehensive Reliability Plan (CRP). NYISO’s Management Committee is scheduled to review the current draft of the CRP on October 29, 2025.

MIDCONTINENT INDEPENDENT SYSTEM OPERATOR (MISO)

Transmission Model Planning

FERC granted in part and denied in part a complaint from Invenergy Transmission against MISO alleging MISO’s tariff is unjust and unreasonable for not providing a transparent and well-defined process to incorporate advanced-stage Merchant High Voltage Direct Current (MHVDC) transmission facilities in MISO’s base case analysis, as part of MISO’s Transmission Expansion Plan. In its order, FERC ruled that MISO’s tariff “is not sufficiently clear as to when and how MHVDC transmission projects are incorporated into MISO’s transmission models.” FERC’s order directs MISO to make a compliance filing to specify when and how MISO will incorporate MHVDC transmission projects into its transmission planning process.

--------------------

[1] Per the CPUC’s Rules of Practice and Procedure Rule 14.3, comments on proposed decisions are due 20 days after issuance of the proposed decision, and reply comments are due five days thereafter.  Comments on draft resolutions are due 20 days after the draft resolution appears in the CPUC’s daily calendar, per Rule 14.5.