RTO Markets

For the sake of profitability and compliance, understanding the workings of regional-transmission organization (RTO) markets is of utmost importance to any business. This applies equally to companies that are embedded within an RTO and to those outside its boundaries.

The Troutman Sanders Energy practice has a national perspective and experience in organized RTO markets. We assist clients with issues concerning RTOS and independent system operators (ISOs) across the United States, including in California, the Midwest, New England and New York, and the Southwest Power Pool.

Our diverse set of clients includes the following:

  • Participating transmission owners (investor-owned and governmental entities)
  • Independent generators
  • Independent transmission developers
  • Utilities on the borders of RTOs

Our lawyers have experience with all areas of RTO policy development and stakeholder participation, including the following:

RTO formation, market design, membership and exit

  • Represented a variety of stakeholders on numerous issues concerning the RTO market design and implementation.
  • Counseled Western transmission-owning utilities in issues related to the development of a Western Energy Imbalance Market.
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Resource adequacy, capacity markets, interconnection and station power

  • Advised a midwestern utility with regard to the Midcontinent ISO tariff filings and stakeholder proposals on resource adequacy. Represented a transmission-owning member of PJM in a FERC proceeding on capacity market design. Also represented a generation owner in the NYISO in a FERC proceeding on capacity market implementation issues.
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Transmission development and cost allocation

  • Represented a midwestern utility in proceedings related to Midcontinent ISO’s transmission cost-allocation methodology.
  • Defended participating transmission owners in a complaint against prudency of formula rate costs.
  • Represented a Midwest utility regarding implementation and conversion from a stated rate to a formula-transmission rate and qualification for transmission-rate incentives.

Integration of renewables, demand response and smart grid

  • Counseled independent generation developers on issues related to participation of renewable resources in the RTO markets.
  • Represented a demand-response aggregator in seeking support and guidance relating to accounting issues associated with revenues from the PJM programs.

Congestion-revenue rights and financial-transmission rights

  • Represented a New York transmission owner in a case regarding its allocation of transmission congestion contracts (TCCs) in the New York ISO market.
  • Represented the California ISO regarding a FERC proposal for long-term transmission rights.

Reliability and compliance

  • Providing ongoing counsel and advice to electric utilities regarding the establishment and enforcement of new mandatory North American Electric Reliability Corporation reliability standards pursuant to the Energy Policy Act of 2005.
  • Provided counsel and assistance with numerous utility audits and investigations by FERC’s Office of Enforcement regarding compliance with FERC’s Standards of Conduct, Code of Conduct, and OASIS regulations and compliance with the utilities’ open-access transmission tariffs.
  • Provided guidance and strategic advice for meetings with Office of Enforcement senior staff.

Market-based rate authority

  • Assisted clients in preparing market-based rate applications and evaluating issues related to RTO markets as part of market analysis.
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