September 30, 2026
Regulatory Update for September 30, 2026
(Covering September 23, 2026 - September 29, 2026)
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)
- Pacific Northwest (OPUC, BPA)
Federal Regulatory Agencies
Independent System Operators (ISO) and Regional Transmission Organizations (RTO)
- California Independent System Operator (CAISO)
- Midcontinent Independent System Operator (MISO)
- Data Centers
Click here to download this update as a PDF
State Regulatory Agencies
CALIFORNIA PUBLIC UTILITIES COMMISSION (CPUC or COMMISSION)[1]
Proposed Decisions and Resolutions
Application (A.) 25-07-001 (Application of Southern California Gas Company on Behalf of its Customers, for Approval of Gas Line Extension Allowances)
This decision grants in part and denies in part the application of Southern California Gas Company (SoCalGas), on behalf of its customers, for approval of gas line extension allowances. This decision also approves SoCalGas’s request to revise Tariff Rule Nos. 20 and 21, SoCalGas’s update to the non-residential gas line extension allowance multiplier of 3.1, and SoCalGas’s request to establish a two-way balancing account to track costs associated with approved gas line extension allowances. Finally, this decision approves the calculation of SoCalGas’s forecasted revenue requirement but directs SoCalGas to update its revenue requirement calculations to account for the fact that only five of the original nine projects are approved by this decision.
Application (A.)26-05-002 (Application of Southern California Gas Company and San Diego Gas & Electric Company for Authorization to Implement Revenue Requirement to Enable the Systems Applications Products (SAP) Migration Program)
This decision authorizes SoCalGas and San Diego Gas & Electric Company (SDG&E) (jointly, Sempra Utilities) to establish the SAP Migration Memorandum Account, effective May 1, 2026, to track costs stemming from implementation of the SAP Migration Program Phase 1B, up to a cap of $13.7 million. The decision does not authorize Sempra Utilities to recover costs recorded in the SAP Migration Memorandum Account. Whether, how, and to what extent Sempra Utilities may recover costs tracked in this memorandum account will be determined in a future Commission decision.
Applications (A.) 22-05-015/016 (Applications of Southern California Gas Company and San Diego Gas & Electric Company for Authority, Among Other Things, to Update its Gas Revenue Requirement and Base Rates Effective on January 1, 2025)
This decision denies the November 25, 2025 petition to modify Decision (D.) 24-12-074, Decision Addressing the 2024 Test Year General Rate Cases of Southern California Gas Company and San Diego Gas & Electric Company (the Decision), filed by the Natural Resources Defense Council, CALSTART, Inc., Powering America’s Commercial Transportation, Advanced Energy United, Tesla, Inc., Walmart Inc., the City of San Diego, Electrify America, LLC, EVgo Services, LLC, and the Electric Vehicle Charging Association (collectively, Joint Petitioners). Joint Petitioners request modification of the Decision to remove the funding cap for the Electric Rule 45 Electric Vehicle Infrastructure Memorandum Account and ensure that Rule 45 remains open to all eligible applications through at least the current rate case cycle, as required by Public Utilities Code section 740.19. According to the decision, the Joint Petitioners’ request is denied because the Commission does not find that the Joint Petitioners presented any new or changed facts within the meaning of Rule 16.4(b). The decision also finds that they used the petition for modification improperly to allege legal errors outside the 30-day window for an application for rehearing.
Rulemaking (R.) 25-09-004 (Order Instituting Rulemaking to Enhance Demand Response in California)
This decision authorizes bridge funding for the 2028–2029 demand response (DR) programs operated by Pacific Gas and Electric Company (PG&E), SDG&E, and Southern California Edison Company (SCE), (collectively, the IOUs), to ensure program continuity while the Commission considers DR reforms in this rulemaking. In addition, the decision modifies the November 1, 2026, filing deadline for the next IOU DR applications to November 1, 2028, to align the applications with the policy updates expected in this rulemaking. The next applications will cover program years 2030–2034. For the Emergency Load Reduction Program pilot, the Commission limits pilot sub-groups and reduces the minimum dispatch hours to ensure the pilot’s availability through the bridge year period, retain continuity for participants, and increase value for ratepayers. Also, the Commission exempts the 2028–2029 DR bridge portfolios from the Societal Cost Test requirement while directing the IOUs to implement Societal Cost Test capability in their DR Cost-Effectiveness Reporting Tools by April 1, 2028, in time for the 2030–2034 program cycle.
Application (A.) 22-015/016 (Applications of Southern California Gas Company and San Diego Gas & Electric Company for Authority, Among Other Things, to Update its Gas Revenue Requirement and Base Rates Effective on January 1, 2025)
This decision evaluates SDG&E’s costs recorded in its wildfire mitigation plan memorandum account (WMPMA) for 2023, and for SDG&E’s drone program costs from 2019–2023. This decision also addresses SoCalGas’s and SDG&E’s Pipeline Safety Enhancement Plan (PSEP) costs carried over from Track 1 of this proceeding, D.24-12-074. In SDG&E’s application for recovery of WMPMA costs, SDG&E seeks recovery of costs recorded in its WMPMA for 2023, above amounts authorized by the Commission in SDG&E’s 2019 Test Year General Rate Case (GRC), D.19 09-051. The amount requested includes recovery of direct operations and maintenance (O&M) costs totaling $254.296 million (and indirect O&M costs totaling $12.512 million) and direct capital expenditures of $404.696 million (and indirect capital expenditure costs of $58.841 million), for a total cost request of $730.345 million. SDG&E also seeks recovery of drone inspection and repair costs for the 2019 to 2022 period in the above amounts, for which resolution was continued to this track, as required by the Track 2 GRC decision. After accounting for the Interim Rate Recovery SoCalGas already collected for the PSEP Balancing Account, as well as the disallowances noted in the decision, the Commission authorizes SoCalGas to recover the remaining undercollected revenue requirement through 2026 of $19.812 million via their next scheduled rate change. The 2027 revenue requirement for revenue requirement associated with PSEP costs shall be implemented in rates on January 1, 2027, or with the next scheduled rate change for that year, through a Tier 1 Advice Letter.
Rulemaking (R.) 21-06-017 (Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future)
This decision orders PG&E, SCE, and SDG&E, (collectively, IOUs), to retain a consultant to lead a series of working group meetings to vet proposals for a common Distributed Energy Resources (DER) orchestration framework, and prepare a report with recommendations based on the stakeholder feedback in the workshops. The report will be included as an attachment to the Joint IOU Application to be filed within 12 months of the issuance of this decision. This decision also directs the IOUs to organize a full-day stakeholder workshop presenting new Load Flexibility Scenarios that they will incorporate as a fourth modeling scenario in the annual Distribution Planning and Execution Process (DPEP) starting with the 2027–2028 cycle. This decision directs the IOUs within 75 calendar days of this decision to hold a workshop to present their proposals for a Load Flexibility Scenario as a fourth scenario within the existing DPEP Scenario Planning Framework. The decision directs the IOUs to file a joint Tier 3 advice letter within 60 calendar days after the workshop providing the technical basis for Load Flexibility Scenario inputs and proposing implementation timing.
Rulemaking (R.18-04-019) (Order Instituting Rulemaking to Consider Strategies and Guidance for Climate Change Adaptation)
In this decision, the Commission declines to adopt modifications to existing General Orders or adopt a new General Order to address Climate Adaptation. Rather, the Commission adopts the framework proposed by Safety Policy Division with modifications. Upon issuance of this decision, this framework will apply to new applications filed by any IOU that is required to file both Climate Adaptation Vulnerability Assessments and Risk Assessment Mitigation Phase applications in the future. This currently includes PG&E, SCE, SoCalGas, and SDG&E.
Application (A.) 25-04-006 (Application of Southern California Gas Company for Adoption of a Microgrid Optional Tariff)
This decision denies, without prejudice, SoCalGas’s request for authorization to offer the Microgrid Optional Tariff (MOT), primarily because SoCalGas has failed to meet its burden of demonstrating that the proposed tariff is reasonable and in the public interest. The purpose of MOT was to enable the utility to design, build, own, operate, and maintain behind-the-meter and off-grid microgrid facilities within SoCalGas’s service territory. Because the Commission denies SoCalGas’s request, the Commission need not determine the program-design requirements that would apply if the MOT were approved.
Voting Meeting
The CPUC will hold a voting meeting on October 1, 2026 in Sacramento, California, at 11 a.m. PT. The energy-related agenda items are below:
Item 2. Resolution E-5455
This resolution approves PG&E’s Advice Letter (AL) 7785-E, filed on December 18, 2025, requesting Commission approval of an exceptional case agreement between PG&E and Google LLC to support the energization of a new 250-megawatt (MW) transmission-level retail electric load at 230 kilovolts (kV) in San Jose, California. The resolution approves the AL with modifications, requiring additional ratepayer protections.
Item 4. Rulemaking (R.) 15-05-006 (Order Instituting Rulemaking to Develop and Adopt Fire-Threat Maps and Fire-Safety Regulations)
This decision partially grants a petition for modification of D.17-12 024, filed by SCE for modifications to the boundaries of the High Fire-Threat District in its service territory. SCE’s proposed addition of 47 areas to the High Fire-Threat District is approved while removal of 61 areas from the High Fire-Threat District is denied. The Commission’s Safety Policy Division is directed to hold a workshop in 2027 on future proposed modifications to the Commission’s High Fire-Threat District Map. Some incremental costs may result from implementation of the Commission’s fire-safety regulations; cost recovery for any such costs is consistent with D.17 12-024.
Item 6. Resolution G-3622
This resolution approves in part and modifies in part the California Energy Commission’s (CEC) ALs 12-G and 10-G-A, filed on August 8, 2025 and October 3, 2025, respectively. These ALs contain proposed Gas Research, Development, and Demonstration (RD&D) Investment Plans (Gas RD&D Plans or Plans) for Fiscal Years 2024–2025 (the 2024 Plan) and 2025–2026 (the 2025 Plan). This resolution approves, in part, the CEC’s Gas RD&D Plans with proposed budgets of $24 million each for its 2024 Plan and its 2025 Plan, totaling $48 million. This resolution reviews the CEC’s 2024 Plan and 2025 Plan against a list of consolidated requirements from prior decisions and resolutions. This resolution finds that CEC Plan omissions can be remedied with additional information and directs the CEC to submit its revised 2024 and 2025 Gas RD&D Plans via Tier 2 ALs within 90 days.
Item 7. Rulemaking (R.) 24-10-005 (Order Instituting Rulemaking to Consider Proposed Changes to General Order 95 to Modernize the Rules and Regulations Governing the Design and Construction of Overhead Electric and Communications Facilities in California)
General Order (GO) 95 provides rules governing the design, construction, and maintenance of overhead lines for electric and communications facilities in California. This decision (a) modifies GO 95 to adopt a new methodology based on Load and Resistance Factor Design (LRFD) in place of Working Stress Design (WSD), (b) revises GO 95 language accordingly, and (c) requires utilities to participate in a workshop and write a subsequent workshop report.
Item 8. Application (A.) 24-01-020, et al., (In the Matter of the Application of SFPP, L.P. for Authority to Increase Rates for Transportation of Refined Petroleum Products)
In its consolidated applications, SFPP, L.P. (SFPP) seeks to increase its existing rates and charges for intrastate transportation of refined petroleum products for the period covering 2021–2024. This decision finds that SFPP’s connected terminals are pipeline system jurisdictional assets per Public Utilities Code section 227.
Item 9. Application (A.) 25-05-009 (Application of Pacific Gas and Electric Company for Authority, Among Other Things, to Increase Rates and Charges for Electric and Gas Service Effective on January 1, 2027)
This decision sets the effective date for the revenue requirement the Commission adopts in PG&E’s General Rate Case (GRC) for the 2027 Test Year is January 1, 2027, even if the Commission adopts the final decision authorizing the 2027 GRC revenue requirement after that date. If the Commission adopts a decision authorizing the 2027 revenue requirement after January 1, 2027, PG&E is authorized to use the General Rate Case Gas Distribution Memorandum Account, the General Rate Case Electric Memorandum Account, and the General Rate Case Gas Transmission and Storage Memorandum Account to track and recover any over-collection or under-collection.
Item 11. Application (A.) 25-04-014 (Application of San Diego Gas & Electric Company to Revise its 2024–2031 Energy Efficiency Rolling Portfolio Business Plan)
This decision rejects the application of SDG&E to modify its energy efficiency business plan and withdraw from administering regional energy efficiency programs, for both electric and natural gas customers, in its service area. The decision finds that the application is both premature and unsupported by the record. SDG&E is required to continue performing administrative duties to deliver its regional energy efficiency program portfolio, including its codes and standards programs. SDG&E is encouraged to modify or cancel underperforming programs and/or rebalance its regional portfolio budget in order to continue to improve the performance of its energy efficiency portfolio overall.
Item 13. Application (A.) 25-04-020 (Application of Southern California Gas Company to Recover Costs Recorded in the Transmission Integrity Management Program Balancing Account from January 1, 2019 to December 31, 2023)
This decision grants SoCalGas’s request for cost recovery in the amount of $81.3048 million as part of its Transmission Integrity Management Program Balancing Account. The Commission disallows $92.4952 million from the original requested amount.
Item 14. Application (A.) 25-05-004 (Application of Southern California Gas Company for Incremental Funding for Customer Information System Replacement Program)
This decision denies SoCalGas’s request for incremental funding to implement its Customer Information System Replacement Program (CIS Replacement Program). The Commission finds that parties to this proceeding have provided evidence that the costs of SoCalGas’s CIS Replacement Program are not likely to exceed the authorized amount the utility has been approved to seek ratepayer recovery for, as provided by the Commission in D.24-12-074.
Item 15. Resolution E-5483
This Resolution approves PG&E’s AL 7860-E, the Diablo Canyon Extended Operations Balancing Account (DCEOBA) True-Up AL filed pursuant to Senate Bill 846 and D.23-12-036, and denies the protest filed by The Utility Reform Network (TURN). PG&E’s AL 7860-E trues-up PG&E’s recorded Diablo Canyon Power Plant (DCPP) extended operations costs and market revenues to the Commission-adopted forecast for the record period September 1, 2023 through December 31, 2025. This resolution finds that PG&E’s recorded DCEOBA costs, totaling approximately $1,224.1 million, are below 115 percent of the approximately $1,325.4 million forecast approved in D.24-12-033, so that no further reasonableness review of those costs is required under Public Utilities Code section 712.8(h)(1). This Resolution also finds that TURN's proposal to apply the 115 percent threshold separately to each individual cost category, rather than to PG&E’s total recorded costs, is not supported by the statute.
Item 18. Rulemaking (R.) 19-03-009 (Order Instituting Rulemaking to Implement Senate Bill 237 Related to Direct Access)
This decision denies Alliance for Retail Energy Markets, California Coalition of Large Energy Users, Direct Access Customer Coalition, Regents of the University of California, Shell Energy North America (U.S.), L.P., and Western Power Trading Forum’s petition for modification of D.21-06-033. According to the decision, the petition fails to satisfy the requirements of Rule 16.4(b) and 16.4(d) of the Commission’s Rules of Practice and Procedure.
Item 20. Resolution E-5476
The Avoided Cost Calculator (ACC) is used in cost-effectiveness analysis of DERs programs and policies. This Resolution provides a link to the final 2026 ACC and related documentation and data files, consistent with policies adopted in D.16-06-007, D.19-05-019, D.22-05-002, D.24-07-015, D.24-08-007, and D.25-11-005. The documentation provides additional detail about this update, including a comparison of the 2026 and 2024 ACC outputs. This Resolution describes the data and major modeling updates to the 2026 ACC.
Item 24. Resolution E-5469
This Resolution approves PG&E’s contract amendment to the Bioenergy Renewable Auction Mechanism (BioRAM) Program power purchase agreement (PPA) with Burney Forest Products to extend the term of the PPA from October 31, 2027 to October 31, 2032.
Item 47. Application (A.) 25-06-017 (Application of Liberty Utilities (CalPeco Electric ) LLC for Authority to Recover Costs Related to the 2020 Mountain View Fire Recorded in the Wildfire Memorandum Account)
This decision authorizes Liberty Utilities to recover approximately $58.05 million in costs related to the 2020 Mountain View Fire recorded in Liberty’s Wildfire Expense Memorandum Account, plus up to an additional $3.375 million in additional financing costs related to the five-year recovery period, along with seventy-five percent of the five unresolved claims. Liberty shall use a Tier 2 advice letter process for approval of the Wildfire Expense Memorandum Account costs related to the unresolved Mountain View Fire claims paid after January 23, 2026. A five-year amortization period will be used by Liberty to recover the authorized Wildfire Expense Memorandum Account costs through a volumetric surcharge on customer bills.
Item 48. Rulemaking (R.) 22-12-011 (Order Instituting Rulemaking to Address Biomethane Procurement Cost Allocation)
This decision finds that all investor-owned gas utility customers should pay a share of the above-market costs of the Renewable Gas Standard (RGS) program. However, the allocation of costs is not extended to non-core customers at this time, pending further assessment of whether an exemption (either in whole or in part) should apply to non-core customers. An additional process on this matter is needed to identify whether and how to implement cost allocation in a way that avoids emissions leakage and encourages industry to stay in California. This decision orders the joint gas utilities to lead a workshop process and subsequently file an application that considers recommendations coming out of the workshop as to whether and how these issues should be addressed.
Item 48A. Rulemaking (R.) 22-12-011 (Order Instituting Rulemaking to Address Biomethane Procurement Cost Allocation)
This Alternate Proposed Decision (APD) finds that all investor-owned gas utility customers should pay a share of the above-market costs of the Renewable Gas Standard (RGS) program, and allocates costs to both core and non-core customers. The APD similarly directs the utilities to lead a workshop process and subsequently file an application.
Events
Interconnection Discussion Forum
Energy Division staff will host the next Interconnection Discussion Forum (IDF) on Tuesday, November 3, 2026 from 1 p.m. to 4 p.m. PT. The IDF provides an informal venue for utilities, developers, and other stakeholders to explore a variety of issues related to interconnection practices and policies. It is generally scheduled quarterly. The November IDF meeting will focus on interconnection issues relating to community solar, under both the Wholesale Distribution Access Tariff and Electric Rule 21. Additional details are available on the Rule 21 website, here.
CALIFORNIA ENERGY COMMISSION (CEC)
2026 Integrated Energy Policy Report (IEPR) Update
The CEC has set the following preliminary schedule for the 2026 IEPR. The schedule is available on the 2026 IEPR Update page.
| Task/Event | Date |
|---|---|
| • Final 2026 IEPR Update Scoping Order released | April 2026 |
| • Adopt order instituting informational proceeding | May 2026 |
| • Public workshops on specific topics | May–December 2026 |
| • Release draft 2026 IEPR Update | October 2026 |
| • Release proposed 2026 IEPR Update | January 2027 |
| • Adopt 2026 IEPR Forecast | January 2027 |
| • Adopt 2026 IEPR Update | February 2027 |
The CEC’s 2026 IEPR Update workshop schedule (which remains subject to change) is set forth below. According to the workshop schedule, all workshops will be held via Zoom and the remaining workshops through December 2026 will run as follows:
November 12, 2026: Commissioner Workshop on Load Modifier Draft Results, 10 a.m.–5 p.m. PT.
December 14, 2026: Commissioner Workshop on Overall Forecast Results, 10 a.m.–5 p.m. PT.
Notice to Amend Electric Vehicle (EV) Charger Reliability Standards
On August 11, 2026, the CEC announced its proposed rulemaking to amend the EV Charger Data and Reliability Standards (set forth in Title 20, California Code of Regulations, Division 2, Chapter 12, Article 2) to exempt MW Charging System EV chargers from certain requirements and to provide other “minor refinements” within the regulations. The CEC held a public meeting to consider the proposed regulations on Thursday, September 24, 2026 from 10 a.m. to 1 p.m. PT via Zoom. Additional information regarding the EV Charger Data and Reliability Standards is available on the EV Charger Data and Reliability Standards webpage.
Interoperability Workshop
The CEC will host a remote-access workshop on November 4, 2026 from 9 a.m. to 1 p.m. to solicit stakeholder feedback on advancing energy interoperability standards in California. The workshop will focus on alignment among communication protocols and standards, including OpenADR 3.1, Matter, IEEE 2030.5, ISO 15118, Open Charge Point Interface (OCPI), and Open Charge Point Protocol (OCPP), to support scalable, privacy-preserving automation and consumer-authorized control. The CEC seeks input from stakeholders including original equipment manufacturers (OEMs), utilities, aggregators, DER providers, consumer advocates, and other interested parties regarding interoperability for the Market Informed Demand Automation Server (MIDAS), Demand Side Grid Support (DSGS), load flexibility, electric vehicle supply equipment (EVSE), and customer energy management systems. Additional workshop information, including login details, is available here.
Electric Program Investment Charge (EPIC)
The CEC hosted its annual EPIC Symposium on September 29, 2026, both in person at the California Natural Resources Agency building at 715 P Street in Sacramento, California and via remote access. EPIC discussion topics included (1) Optimizing EVs as Grid Assets and (2) Closing the Battery Lifecycle Loop. The revised EPIC Symposium agenda is available here.
Opt-In Certification Program: Emergency Rulemaking
On October 9, 2026 from 1:00 p.m. to 4:00 p.m., the CEC will host a remote-access workshop to seek public comments regarding proposed emergency regulations for the Opt-In Certification Program that will be set forth in Title 20, California Code of Regulations, sections 1875-1882, and Appendix B. According to the workshop notice, the proposed changes include, among other things:
- incorporation of the statutory presumption of net economic benefits;
- incorporation of new statutory requirements for applicants to provide evidence of property rights to the proposed location and consultation with the fire suppression authority;
- clarification of the procedures for suspension and early termination of a project application, restructure local agency reimbursement, refine the community benefits agreement process, address post-certification change in project ownership or operational control, and update the Appendix B information requirements applicable to the Opt-In Certification Program.
Written comments on the proposed emergency regulations are due to the Docket Unit by 5:00 p.m. on October 12, 2026.
Lithium Valley Informational Proceeding
The CEC hosted a remote-access workshop on September 10, 2026 to discuss current opportunities for development of the lithium industry in the Salton Sea region of California. Additional information regarding the scope of the workshop is available in the workshop notice. Written comments are due to the docket unit by 5:00 p.m. PT on September 30, 2026.
Wave and Tidal Energy
The CEC released the Draft Senate Bill 605 Wave and Tidal Energy Report to the Governor and Legislature and will be holding a remote-access workshop on September 30, 2026 to present and gather feedback on the draft report. The meeting schedule for the workshop is available here. Written comments on the draft report are due to the docket unit by 5:00 p.m. PT on November 3, 2026.
CEC Business Meetings
The next CEC business meeting is scheduled for October 19, 2026.
PACIFIC NORTHWEST (OPUC, BPA)
Public Utility Commission of Oregon (OPUC)
On September 3, 2026, the OPUC held (1) a public meeting to consider granting PacifiCorp d/b/a Pacific Power’s request for a waiver of OAR 860-089-0250(1) and approving use of PA Consulting as the Independent Evaluator for Phase 2 of PacifiCorp’s 2025 Request for Proposals (Docket No. UM 2383), and (2) a public hearing and commissioner work session to open a formal rulemaking to implement Senate Bill 845, which primarily authorizes OPUC to order the sale of a water utility that is unable to provide safe and adequate service (Docket No. AR 673). The full agenda is accessible here.
Bonneville Power Administration (BPA)
On August 31, 2026, BPA hosted a BP-26 transmission settlement commitment workshop to discuss (1) the short distance discount and the billing determinant for Network Integration Transmission Service as related to behind-the-meter resources and (2) to provide clarity on the scope, eligibility, and costs of the New Generation Technology Pilot Program. The settlement is included in the BP-26 Rate Proceeding Administrator’s Final Record of Decision. More information on the BP-26 rate case is here. On September 1, 2026, BPA hosted the second workshop in its Risk Mitigation & Financial Policies Refresh series, wherein BPA reviewed the existing 2022 Financial Plan which will culminate in a new financial plan, targeting a 2027 publishing date, to ensure BPA’s long-term financial goals are supported with agile risk mitigation strategy and updated financial policies. The 2022 Financial Plan is available here.
Also on August 31, 2026, BPA published what it refers to as a refreshed strategic plan to accelerate innovative transmission and power supply solutions to meet growing demand and expansion in the region. The plan seeks to protect legacy customers and ratepayers by ensuring that “growth pays for growth.” The 2026–2030 Strategic Plan is available here.
Lastly, on September 1, 2026, BPA announced a two-week delay in issuing its updated large generator interconnection Phase One Cluster Study Reports. Those reports—initially targeted for September 11, 2026—were issued September 25, 2026. In addition, BPA will tender Phase Two Cluster Study Agreements on October 9, 2026 for customers who intend to move forward in the interconnection study process.
Federal Agencies
U.S. DEPARTMENT OF ENERGY (DOE)
DOE Awards $1.9 Billion for Grid Projects
DOE announced it intends to fund 31 grid-improvement projects across 26 states as part of the Department’s Speed to Power through Accelerated Reconductoring and other Key Advanced Transmission Technology Upgrades (SPARK) initiative. DOE stated that the projects will receive $5.25 billion in total, $1.9 billion in federal funding from DOE and $3.35 billion in recipient cost-share funding, to improve grid reliability and lower electricity costs.
FEDERAL ENERGY REGULATORY COMMISSION (FERC)
FERC 2026 Commission Meeting Summary
FERC held its September 2026 Commission Meeting on September 10, 2026. FERC released orders on the following:
- North American Electric Reliability Corporation’s (NERC) proposed reliability standard (RD26-9-000): This order approved NERC’s proposed physical Reliability Standard CIP-014-4 and the associated implementation plan, violation risk factors, and violation severity levels, as well as the retirement of the currently effective Reliability Standard CIP-014-3. The Physical Security Standard requires applicable transmission owners to perform a periodic risk assessment to identify critical transmission substations, evaluate potential threats and vulnerabilities of a physical attack, and develop a physical security plan to protect critical facilities.
- FERC’s show-cause proceeding against ISO New England, Inc. (ISO-NE) related to ISO-NE’s lack of mechanism to allow ISO-NE to adjust erroneous capacity performance payments (EL26-45-000): This order found ISO-NE’s tariff unjust and unreasonable because it lacks provisions that would enable ISO-NE to accept payments from market participants that were erroneously or improperly received, which yields unjust and unreasonable market outcomes for market participants and customers. ISO-NE must submit a compliance filing within 120 days of the date of the order.
- Tri-State Generation and Transmission Association, Inc.’s (Tri-State) participation in Southwest Power Pool’s (SPP) expansion into the Western Interconnection (SPP West) (ER20-681-016): The order conditionally accepts Tri-State’s tariff revisions that reflect its participation in the SPP West. The order requires Tri-State to offer its SPP West units at or below each unit’s mitigated energy offer and to submit a compliance filing that provides a horizontal market power analysis of the SPP West market.
- TransAlta Energy Marketing (U.S.) Inc.’s spot sales above the Western Electricity Coordinating Council (WECC) soft cap (ER23-276-000): This order found under Mobile-Sierra that there is no basis for further FERC action concerning TransAlta Energy Marketing (U.S.) Inc.’s spot market energy sales that exceeded the WECC soft price cap of $1,000/MWh.
- Mercuria Energy America, LLC’s spot sales above the WECC soft cap (ER23-450-000): This order found under Mobile-Sierra that there is no basis for further FERC action concerning Mercuria Energy America, LLC’s spot market energy sales that exceeded the WECC soft price cap of $1,000/MWh.
- Calpine Energy Services, L.P.’s spot sales above the WECC soft cap (ER23-316-000): This order found under Mobile-Sierra that there is no basis for further FERC action concerning Calpine Energy Service, L.P.’s spot market energy sales that exceeded the WECC soft price cap of $1,000/MWh.
Independent System Operators (ISO) and Regional Transmission Organizations (RTO)
CALIFORNIA INDEPENDENT SYSTEM OPERATOR (CAISO)
Stakeholder Initiatives: Upcoming Meetings and Deadlines
Reminder: 2026 CAISO Stakeholder Symposium
The CAISO Stakeholder Symposium will be held on October 5–6, 2026, in Sacramento, CA. The final agenda for October 6 can be found here.
Large Loads Initiative
The CAISO posted the draft final proposal and draft tariff language for the Large Loads Initiative on September 24, 2026. The hybrid public stakeholder meeting will take place October 1, 2026 to discuss the proposal, and a virtual meeting will be held on October 19, 2026. However, registration for the in-person meeting is now closed. Online meeting details can be found here.
Western Energy Markets (WEIM) Regional Issues Forum Meeting
The WEIM Regional Issues Forum has posted the agenda for its upcoming hybrid meeting in Sacramento, CA, from 1 p.m. to 4:30 p.m. Parties may register to attend in person, but registration is not required for virtual attendance.
Demand Response Issues and Performance 2025 Report Posted
The CAISO’s Department of Market Monitoring (DMM) has published the Demand Response Issues and Performance 2025 Report providing analysis of demand response activity for balancing areas across the WEIM.
Interconnection Process Enhancements: Draft Tariff Language Posting
The CAISO posted the draft tariff language for outstanding items related to several interconnection stakeholder on September 15, 2026, which can be found on the initiative webpage. A public stakeholder meeting to discuss the proposed revisions will take place on September 30, 2026.
Storage Design and Modeling: Revised Straw Proposal Posted
The CAISO has posted the Revised Straw Proposal on Default Energy Bids on the Storage Design and Modeling webpage. The revised straw proposal was discussed at the stakeholder meeting that took place on September 22, 2026. Written comments on the revised straw proposal through CAISO’s commenting tool are due by end of day October 6, 2026.
MIDCONTINENT INDEPENDENT SYSTEM OPERATOR (MISO)
MISO Plan to Reduce Interconnection Restudies
MISO filed revisions to Attachment X (Generator Interconnection Procedures) of its tariff that would allow it to “prevent boundless Interconnection Study restudies in Phase III of the Definitive Planning Phase” process.
MISO’s proposal would grant Interconnection customers in the DPP-2022 Cycle a one-time, unconditional opportunity to withdraw from the queue penalty-free at Decision Point II. In exchange, the threshold for penalty-free withdrawal after Decision Point II would be increased. For the DPP-2022 Cycle and thereafter, MISO would limit the number of Phase III restudies to one, if necessary.
Data Centers
DATA CENTERS AND LARGE LOADS
Texas Governor Further Restricts Data Center Permits
Governor Greg Abbott directed the Texas Commission on Environmental Quality (TCEQ) to halt all permits sought by data centers until the Electric Reliability Council of Texas (ERCOT) completes its data center review. Governor Abbott’s letter follows his previous directives in the past month to the Public Utility Commission of Texas and ERCOT to verify and audit all data centers advancing through ERCOT’s interconnection process. Governor Abbott also directed TCEQ to ensure that its permitting decisions align with his directives, noting that data center projects must cover their own electrical infrastructure costs with lower residential electric bills. In his letter, Governor Abbott noted that TCEQ shall provide an update on its compliance by October 19, 2026.
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[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.
Media Contact
Jamie Moss (newsPRos)
Media Relations
w. 201.493.1027 c. 201.788.0142
Email
Key Contributors
- Partner
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- Associate
- Associate
- Associate
Practice Areas
Industries
Chapters
- Energy Regulatory Updates
- Energy-Related Executive Orders and Memorandum
- October 21, 2026
- October 14, 2026
- October 7, 2026
- September 30, 2026
- September 23, 2026
- September 16, 2026
- September 10, 2026
- September 2, 2026
- August 26, 2026
- August 19, 2026
- August 12, 2026
- August 5, 2026
- July 29, 2026
- July 22, 2026
- July 15, 2026
- July 8, 2026
- July 1, 2026
- June 24, 2026
- June 17, 2026
- June 10, 2026
- June 3, 2026
- May 28, 2026
- May 20, 2026
- May 13, 2026
- May 6, 2026
- April 29, 2026
- April 22, 2026
- April 15, 2026
- April 8, 2026
- April 1, 2026
- March 25, 2026
- March 18, 2026
- March 11, 2026
- March 4, 2026
- February 25, 2026
- February 19, 2026
- February 11, 2026
- February 4, 2026
- January 28, 2026
- January 22, 2026
- January 14, 2026
- January 7, 2026
- December 31, 2025
- December 17, 2025
- December 10, 2025
- December 3, 2025
- November 26, 2025
- November 19, 2025
- November 12, 2025
- November 5, 2025
- October 29, 2025
- October 22, 2025
- October 15, 2025
- October 8, 2025
- October 1, 2025
- September 24, 2025
- September 17, 2025
- September 10, 2025
- September 3, 2025
- August 27, 2025
- August 19, 2025
- August 12, 2025
- August 5, 2025
- July 29, 2025
- July 22, 2025
- July 15, 2025
- July 8, 2025
- July 1, 2025
- June 24, 2025
- June 17, 2025
- June 10, 2025
- June 3, 2025
- May 28, 2025
- May 20, 2025
- May 13, 2025
- May 6, 2025
- April 29, 2025
- April 22, 2025
- April 15, 2025
- April 8, 2025
- April 1, 2025
- March 26, 2025
- March 18, 2025
- March 11, 2025
- March 4, 2025
- February 25, 2025
- February 19, 2025
- February 11, 2025
- February 4, 2025
- January 28, 2025
- January 22, 2025
- January 14, 2025
- January 7, 2025
- December 20, 2024
- December 17, 2024
- December 10, 2024
- December 3, 2024
- November 26, 2024
- November 19, 2024
- November 12, 2024
- November 5, 2024
- October 29, 2024
- October 22, 2024
- October 15, 2024
- October 8, 2024
- October 1, 2024
- September 24, 2024
- September 17, 2024
- September 10, 2024
- September 4, 2024
- August 27, 2024
- August 20, 2024
- August 13, 2024
- August 6, 2024
- July 30, 2024
- July 23, 2024
- July 16, 2024
- July 9, 2024
- July 2, 2024
- June 25, 2024
- June 18, 2024
- June 11, 2024
- June 4, 2024
- May 29, 2024
- May 21, 2024
- May 14, 2024
- May 7, 2024
- April 30, 2024
- April 23, 2024
- April 16, 2024
- April 9, 2024
- April 2, 2024
- March 26, 2024
- March 19, 2024
- March 12, 2024
- March 5, 2024