The Federal Energy Regulatory Commission (FERC) published a combined notice in the Federal Register on December 2, 2025, detailing a series of electric rate filings submitted between October 30 and November 10, 2025. This notice, under Volume 90, Number 229, compiles updates from utilities, power marketers, and regional transmission organizations across the United States. It addresses matters ranging from market-based rate authorizations to compliance filings and generator interconnection agreements. The significance of this compilation lies in its reflection of ongoing regulatory activities that ensure fair competition, reliable transmission, and compliance with federal energy laws. By aggregating these filings, FERC provides transparency and an opportunity for public intervention or protest, which is crucial for stakeholders in the evolving energy landscape.
Background on FERC's Role and Filing Processes
FERC oversees the wholesale sale and transmission of electricity in interstate commerce, as authorized by the Federal Power Act. Electric rate filings, submitted under Section 205 of the act, allow entities to propose or amend rates, terms, and conditions for services. These can include requests for market-based rate authority, which permits sellers to charge flexible prices rather than cost-based rates, provided they lack market power. The combined notice serves as a procedural tool to inform the public and invite comments, with deadlines typically set two to three weeks after filing.
This particular notice encompasses 28 docket numbers, involving diverse applicants such as investor-owned utilities, independent power producers, and regional entities like Southwest Power Pool (SPP) and PJM Interconnection. For instance, filings from Aron Energy Prepay LLC affiliates and J. Aron & Company LLC report non-material changes in status, which are required when ownership or market conditions shift but do not fundamentally alter market power assessments. Such updates stem from FERC's triennial market power analysis requirements, ensuring ongoing compliance.
Key Filings and Applicants
Several filings highlight adjustments in market participation and infrastructure. Public Service Company of New Mexico submitted a supplement to a notice of non-material change in status (Docket ER10-2302-011) and a compliance filing amendment (Docket ER25-1815-001), effective May 16, 2025. These relate to updates in its operational status, potentially tied to changes in generation assets or affiliate relationships.
A cluster of dockets from Aron Energy entities (ER20-391-016 and others) involves notices of non-material changes, filed on October 31, 2025. These entities, affiliated with commodity trading firm J. Aron & Company LLC, operate as power marketers. The filings likely address minor shifts, such as asset acquisitions, without triggering a full market power review.
Regional transmission organizations feature prominently. SPP submitted multiple filings, including compliance revisions to its tariff (Docket ER25-2430-002) and several generator interconnection agreements (GIAs) with Omaha Public Power District (OPPD), such as Dockets ER26-459-000 through ER26-467-000. These involve cancellations of interim GIAs and new agreements effective October 24 or 27, 2025, facilitating the integration of new generation into the grid.
PJM Interconnection, managing the largest U.S. electricity market, filed periodic reviews of its variable resource requirement curve (Docket ER26-455-000) and original construction service agreements (CSAs) related to interconnections with the Midcontinent Independent System Operator (MISO), as in Dockets ER26-460-000 and ER26-464-000. These address capacity market parameters and cross-regional coordination, essential for grid reliability.
New market entrants include CDH Vidal LLC and Pediment BESS I LLC, seeking initial market-based rate authority (Dockets ER26-457-000 and ER26-458-000), effective January 5, 2026. These filings indicate emerging projects, possibly in renewables or battery storage, aiming to participate in wholesale markets.
Legal and Political Context
These filings occur amid broader federal energy policy shifts, influenced by precedents like FERC Order No. 697, which established the framework for market-based rates. That order requires sellers to demonstrate lack of horizontal and vertical market power, with changes reported to maintain authorization. Politically, the energy sector faces pressures from the transition to renewables, as seen in filings for solar projects like Bel Air Solar I, LLC's tariff amendment (Docket ER25-3436-001) and Ratts 2 Solar LLC's waiver request (Docket ER26-427-000).
Different perspectives emerge among stakeholders. Utilities and transmission operators view these processes as necessary for grid stability, while consumer advocates may scrutinize rate changes for potential cost increases. Environmental groups often monitor for renewable integration, whereas industry players emphasize the need for streamlined approvals to meet growing demand. FERC's notice invites interventions, allowing these viewpoints to influence outcomes.
Short-term implications include potential approvals that enable new market entries or agreement executions by early 2026. Long-term, these filings contribute to a more interconnected and competitive market, but challenges persist in balancing innovation with reliability, especially amid climate goals and supply chain issues.
Implications and Perspectives
The filings underscore trends in energy market evolution, such as increased battery storage and solar integrations, as evidenced by applicants like Dodge Flat Energy Center, LLC (Docket ER26-469-000). Compliance filings, like SPP's tariff updates, respond to prior FERC directives, ensuring alignment with open access transmission rules.
From a legal standpoint, precedents like the Supreme Court's decision in FERC v. Electric Power Supply Association (2016) affirm FERC's authority over wholesale markets, providing a backdrop for these proceedings. Politically, the filings reflect state-federal tensions, particularly in regions like the Southwest and Midwest, where transmission planning intersects with local policies.
Stakeholders offer varied views. Proponents argue that efficient filings reduce barriers to entry, fostering competition. Critics, including some ratepayer groups, caution against approvals that might concentrate market power. Without endorsing positions, these perspectives highlight the need for vigilant oversight.
In conclusion, this FERC notice encapsulates routine yet critical regulatory activities shaping the U.S. electricity sector. Key takeaways include the emphasis on compliance and market adjustments amid technological shifts. Potential next steps involve public comments leading to FERC orders, with possible hearings if protests arise. Ongoing debates may focus on enhancing grid resilience and integrating clean energy, presenting challenges like regulatory delays and infrastructure needs. As the sector evolves, these processes will continue to balance innovation with equitable access.
