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Crowell & Moring’s attorneys and professionals have been at the forefront of the transformation of the nation’s transmission system brought on by FERC’s Order No. 888. Members of our Energy Group pioneered the drive for open access and comparable service, standardized interconnection, financial congestion management, open regional transmission planning, and competitive ancillary services. Today, transmission is undergoing another transformation, driven by the need to integrate renewable electricity generation, the need for major new transmission infrastructure projects, and the increasing number of companies with new technologies entering transmission development and ownership.

Our Energy Group has substantial experience in all aspects of the transmission business, including the rights and obligations under FERC’s open access transmission tariff, cost-of-service and market-based rate design, incentive rates, large transmission projects, generator interconnection and transmission reliability studies, and unique transmission issues faced by renewable energy companies. We also counsel clients on various aspects of grid services, including the formation and operation of balancing authority areas, negotiation of local area reliability agreements, and the use of energy storage and distributed generation to maintain reliability.

Companies hire the firm not only to navigate existing regulatory hurdles, but to overcome them. Our cutting-edge work gives clients the advantage they need to make their commercial goals a reality.

Representative Engagements: Electric Transmission

  • Imbalance Charges. Represented Invenergy in FERC proceedings involving Puget Sound Energy’s establishment of higher generator imbalance charges to be assessed to wind generators, including Invenergy’s Vantage generating unit.
  • Ten West Line Certificate of Public Convenience and Necessity. Represented DCR Transmission in a proceeding before the California Public Utilities Commission (CPUC) concerning DCRT’s application for a certificate of public convenience and necessity for the Ten West Link transmission project, a proposed 114-mile, 500 kV transmission line that will increase transfer capacity and facilitate delivery of renewable generation between the Arizona and California transmission grids, and assisting DCRT in BLM/CPUC’s environmental review of Ten West Link.
  • Transmission Service. Represented NaturEner USA, LLC in FERC proceedings and commercial negotiations regarding a wind project’s transmission service rights from a merchant transmission provider, and in obtaining FERC approval for a temporary transmission service provided by a neighboring generation facility pending completion of the merchant transmission line.
  • Jurisdictional Agreements. Negotiated and obtained FPA § 205 authorization for, and represented clients in FERC proceedings regarding, various types of jurisdictional services, such as shared facilities arrangements, joint ownership agreements, open access transmission, and waivers from FERC’s open access transmission requirements, including FERC proceedings to obtain reasonable terms for transmission upgrade cost responsibilities, ancillary service cost obligations, and renewal terms.
  • Merchant Transmission. Represented Central Transmission, LLC in FERC complaint proceeding seeking reforms to the PJM tariff to ensure that new entrants have the same rights to propose, build, and receive cost-based compensation for transmission projects as incumbent transmission owners.
  • Certificate for New Transmission Line. Represented CPV Warren in West Virginia Public Service Commission proceedings considering a certificate of need for a new transmission line.

Representative Engagements: Interconnection Services, Agreements & Costs

  • Reduction in Network Upgrade Charges. Represented BP Wind Energy and EDP Renewables in complaint proceedings seeking a reduction in charges assessed by a MISO transmission owner for network upgrades.
  • Bishop Hill and Lackawanna Interconnection Agreements. Represented Invenergy in protesting PJM’s filing of interconnection agreements for its Bishop Hill and Lackawanna generation facilities.
  • CPV Valley Interconnection to NYISO. Represented CPV Valley, LLC regarding its interconnection to the New York Independent System Operator (NYISO) bulk power transmission system and its interests in New York siting regulatory proceedings.
  • Alleged Transmission Owner Discrimination. Represented Renewable Energy Systems Americas in connection with a complaint proceeding alleging discriminatory conduct by transmission owners with respect to interconnection of a wind project in North Dakota.
  • Standardized LGIA Formation. Played a key role in an industry team created by FERC to develop its standardized Large Generator Interconnection Procedures and Agreement and the wind interconnection rules of various RTOs, which formed the basis for FERC’s landmark Order No. 2003.

Representative Engagements: Grid Services

  • Peak Reliability Funding. Represented Western Systems Coordinating Council and Peak Reliability in FERC proceedings to obtain funding through the North American Electric Reliability Corporation for reliability coordination services to be provided by Peak Reliability.
  • Generator-Only Balancing Authority Areas. Represented Duke Energy in establishing generator-only balancing authority areas and balancing authority area services as a separate business line, including drafting of contracts and amending interconnection agreements, obtaining SEC no-action letters, addressing FERC jurisdictional implications of the service arrangements, establishing operating protocols, and participation in reserve sharing pools.
  • Interchange Agreements. Represented generators in reviewing and analyzing interconnection/interchange agreements between utility balancing authority areas regarding responsibilities and liabilities regarding impacts from third-party generators.
  • RMR Agreements. Represented Pittsfield Generating Company, LSP Bridgeport Energy, Milford Power Company, NRG Energy, PSEG Power Connecticut, and Calpine Corporation in connection with reliability must run agreements (RMR).
  • System Restoration Services Tariff. Represented USGen New England, Inc. in drafting a system restoration services tariff and initiating regulatory proceedings to compensate suppliers of blackstart-related system restoration and planning service.
  • Reactive Power Tariffs. Represented generators in filing applications with FERC for, and litigating issues related to, reactive power tariffs and revenue requirements and seeking modifications to reactive power provisions of ISO tariffs.

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Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, and Brussels.

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