Search
January 15, 2026

PJM MIC Briefs: Jan. 7, 2026

Fuel Cost Policy Updates for Manual 15

The Market Implementation Committee endorsed an issue charge to evaluate whether revisions to Manual 15: Cost Development Guidelines are warranted to preclude market sellers from inflating cost-based offers by using inaccurate fuel cost estimates from affiliated suppliers. The issue charge passed with 81.9% support. (See “Fuel Cost Policy Issue Charge,” PJM MIC Tackles Issue Charges, Problem Statements.)

PJM’s David Hauske said the issue charge would memorialize the RTO’s existing practices around approving fuel cost policies.

Joel Romero Luna, an analyst with the Independent Market Monitor, said all of the currently approved fuel cost policies meet the changes contemplated by the issue charge.

Stakeholders questioned how the definition of “affiliate” used in the issue charge might interact with the tariff-defined term. PJM Associate General Counsel Chen Lu said “affiliate” was lowercased intentionally to avoid tying it to the governing document definition.

Manager of Stakeholder Process and Engagement Michele Greening said PJM can revise the issue charge to allow for changes to the governing documents if necessary.

Monitor Reminder for Reviewing Fuel Cost Policies

The Monitor presented a reminder that market participants with fuel cost policies expiring in November 2026 should review the compliance of their policies and update them if needed. Those who fail to extend their policies will be required to submit a new one and either submit cost-based offers priced at zero or use PJM’s temporary cost offer method in the meantime.

PJM Proposes Performance Penalties for Non-emergency Load Management

PJM presented a proposal to assess performance penalties against demand response (DR) resources that do not meet their obligations during a non-emergency load management deployment.

Curtailment service providers (CSPs) that do not meet their obligations would be subject to a penalty rate set at half the charge for capacity resources that fail to respond during a performance assessment interval (PAI), which would be approximately $1,150/MWh for the 2027/28 delivery year. The additional penalties would count toward the annual stop-loss limit capping the amount of capacity performance penalties a resource can be assigned in a delivery year.

PJM’s Pete Langbein said the revenues collected from the penalties would be allocated to load-serving entities (LSEs) as a bonus on the logic that they purchased the capacity CSPs are expected to provide.

According to the problem statement brought by PJM, there were six deployments in the summer of 2025 totaling 30 hours, with a weighted average performance of 67%.

“This is significantly lower than in prior years and much lower than the overall test results of 103% for the [2024/25] DY. PJM expects to dispatch load management (and/or PRD will be required to respond) more frequently in the future due to lower reserve margins,” PJM wrote.

Voltus presented a non-performance penalty based on the IESO market design, which would set charges at the shortfall measured in unforced capacity (UCAP) times the daily capacity rate and a non-performance factor based on event duration. A portion of the penalties would go to overperforming CSPs, and the remainder would be allocated to consumers.

Auction Report Correction

PJM has reposted its report on the 2027/28 Base Residual Auction (BRA) to correct two errors related to the installed reserve margin (IRM).

Langbein said a rounding error on the pool-wide accreditation factor led to the IRM accreditation being understated at 14.4%. The report has been updated to correct that value at 14.9%. (See PJM Capacity Auction Clears at Max Price, Falls Short of Reliability Requirement.)

The report’s executive summary also did not account for price-responsive demand (PRD) when discussing the reserve margin.

PJM Presents Issue Charge on Storage Participation in Energy and Ancillary Service Markets

PJM’s Danielle Croop presented a problem statement and issue charge to expand the capability of the RTO’s energy storage resource (ESR) participation model to account for state of charge, opportunity costs and other participation rules for the energy and ancillary service markets.

Both documents note that PJM has an obligation under FERC Order 841 to incorporate state of charge in storage dispatching in 2026, a gap the RTO wrote can lead to infeasible dispatch instructions.

The problem statement argues a closer look at the ESR model is necessary due to the amount of storage under development in PJM.

“As of November 2025, PJM’s interconnection queue has over 3.5 GW of energy storage under construction, ~1.2 GW in transition cycle 1 and over 9 GW in transition cycle 2. Even if only a portion of these projects become operational, PJM can expect a significant increase in battery storage on its system. As its penetration grows, PJM needs to ensure that its market rules can effectively manage these limited-duration resources,” PJM wrote.

Croop said other RTOs have integrated large amounts of storage in their markets, creating an opportunity for PJM to review other market design elements and their success, such as how storage resources are required to submit offers and their parameters.

The issue charge lists market rules that may be part of the discussion as including “energy must-offer rules, intraday offer rules, uplift eligibility and resource parameters.” It also would open the conversation to whether hybrid resources should be included.

Croop told RTO Insider the energy market must-offer requirement for storage resources is not as cut and dried as for traditional resources. They are required to offer their full capability, measured in UCAP, into the market.

Responding to questions around peak shaving adjustments and load forecasting, Croop said the issue charge is narrowly focused on storage participation in the energy and ancillary service markets. While those are issues worth talking about, that should come with a dedicated issue charge.

Flexible Resource Issue Charge Endorsed

Stakeholders endorsed by acclamation an issue charge seeking to rework the definition of flexible resources, with the aim of reducing instances where resources committed in the day-ahead market on flexible parameters cannot be dispatched on other schedules in the real-time market. (See “1st Read on Flexible Resource Definition Clarification Issue Charge,” PJM MIC Tackles Issue Charges, Problem Statements.)

Flexible resources typically are held offline until committed by PJM or the resource owner self-schedules, with lost opportunity cost (LOC) credits paid to compensate the owner for real-time profits that were missed out on. The flexible definition pertains to resources that can start up within two hours and run for two or fewer hours, known as 2×2 parameters.

If a flexible resource changes either its start time or minimum run time to be longer than three hours, it becomes ineligible for LOC credits and cannot be evaluated by intermediate term (IT) SCED. The issue charge aims to address instances where a flexible offer is not needed, and other inflexible schedules could allow the resource to operate.

PJM’s Susan Kenney gave an example of a resource committed on a flexible schedule in the day-ahead market and which is offer capped due to a market power determination owing to a transmission constraint. If that constraint does not materialize, IT SCED would not be able to consider any of the resource’s other offers with inflexible parameters.

She said PJM has solutions in mind and expects the issue can be addressed within a few months, leading to the issue charge being brought through under the CBIR Lite pathway, which offers a more streamlined stakeholder process.

Stakeholders Endorse Quick Fix on Offline Resource LOC Eligibility

The MIC endorsed by acclamation a quick fix proposal to tighten when secondary reserves are eligible for LOC credits. The quick fix pathway allows for an issue charge to be brought concurrent with a proposed solution. (See PJM MIC Tackles Issue Charges, Problem Statements.)

The proposal addresses instances in which offline resources, which are supposed to be ineligible for LOC, are viewed as being online by settlement calculations and made eligible for credits.

PJM’s Suzanne Coyne said the issue arises due to a discrepancy between settlement and how real-time (RT) SCED determines if a resource is offline. The dispatch software considers a resource offline if it is not operating when assigned a commitment, while the settlement side focuses on whether the unit was operating at the start of that commitment. If the resource begins ramping up between the time it is dispatched and the start of its commitment, it can improperly be considered eligible for LOC credits.

If endorsed by the Markets and Reliability Committee at its Feb. 19 meeting, implementation could begin in March, Coyne said.

Judge Again Lifts Revolution Wind Stop-work Order

A federal judge has lifted the stop-work order against one of the five offshore wind projects shut down by the Trump administration Dec. 22.

The Jan. 12 victory by Revolution Wind mirrored its September 2025 win in the same case, when the same judge lifted an earlier stop-work order issued by the Bureau of Ocean Energy Management. (See Judge Lifts BOEM’s Stop-work Order on Revolution Wind.)

The joint venture of Skyborn Renewables and Ørsted is several months from completion and is designed to send 704 MW of power at peak output to Connecticut and Rhode Island.

Later Jan. 12, Ørsted said construction would resume immediately while the court proceedings continue on the Aug. 22 and Dec. 22 stop-work orders. It said it would continue to look for an expedited and durable resolution with the Trump administration.

In both rulings, U.S. District Judge Royce Lamberth — appointed to the federal bench by former President Ronald Reagan — wrote that Revolution likely was to suffer irreparable harm if the halt remained in place.

Some of the offshore wind developers are making a similar point, framing it as an existential threat.

The move is costing the five remaining U.S. projects millions of dollars a day and jeopardizing tightly orchestrated construction timelines. The specialized installation vessels needed for the projects are booked years in advance and the operators cannot adjust their schedules.

Notably, Empire Wind said in a Jan. 6 court filing that if it cannot resume work by Jan. 16, the project faces likely termination.

Likewise, Sunrise Wind said Jan. 9 that the stop-work order constitutes an enterprise-level threat that is inflicting irreparable harm that will compound if the court does not issue a preliminary injunction by the week of Feb. 1.

The five U.S. projects are in various stages of construction. Some were only a few months from completion when the U.S. Department of the Interior issued a 90-day stop-work order Dec. 22, citing national security. Interior claims some of the reasons are classified secrets and is not making them public or sharing them with the wind developers.

The court fights are the culmination of President Donald Trump’s longstanding dislike of wind power and of the efforts by him and his administration to thwart it starting on Day 1 of his second term. (See All U.S. Offshore Wind Construction Halted and Offshore Wind Developers Fight to get Back in the Water.)

When the nascent U.S. offshore wind sector peaked in the early 2020s, more than a dozen projects were in the pipeline and President Joe Biden set a national goal of 30 GW by 2030. But the grand vision began to fade well before the 2024 presidential election, due to cost, logistical and supply chain challenges.

Since then, Trump’s stance and the risks raised by his policy changes have scared off investors. Further construction appears unlikely any time soon beyond the five existing projects, which total just 5.8 GW of nameplate capacity.

Revolution initiated its court fight Sept. 4. The attorneys general of Connecticut and Rhode Island subsequently joined in.

To submit a commentary on this topic, email forum@rtoinsider.com.

Coastal Virginia Offshore Wind (CVOW) developer Dominion Energy sought a preliminary injunction Dec. 23. It is fighting the Department of Defense’s attempts to withhold the secret reasons for the stop-work order.

Empire developer Equinor challenged the suspension Jan. 2.

Ørsted filed a complaint over Sunrise on Jan. 6 and motioned for a preliminary injunction Jan. 9.

The attorney general of New York, where power would flow from Empire and Sunrise, filed complaints for declaratory and injunctive relief Jan. 9.

All the proceedings were filed in the U.S. District Court for the District of Columbia except for CVOW, which was filed in the Eastern District of Virginia.

Avangrid and Copenhagen Infrastructure Partners have not announced a response to the suspension of Vineyard Wind 1, which is in late stages of construction and already generating power with some of its turbines.

Meanwhile, offshore wind opponents are not resting while all this continues.

ACK For Whales, a coastal Massachusetts 501(c)(3) formed to oppose offshore wind, filed its latest lawsuit Jan. 9 in U.S. District Court for the District of Columbia against Interior. It seeks to overturn regulatory approval of Vineyard Wind 1 on the grounds that it was unlawful.

The Oceantic Network cheered Revolution’s Jan. 12 court win: “The U.S. offshore wind industry has always worked closely with the federal government to ensure national security interests were prioritized in the siting and permitting of every project in federal waters. Oceantic applauds this result to get the project moving again to deliver reliable, affordable power to communities across New England that desperately need it.”

ISO-NE has said Revolution’s expected output already is part of its capacity calculations. (See ISO-NE Warns Halting Revolution Wind Boosts Reliability Risk.)

PJM PC/TEAC Briefs: Jan. 6, 2026

Planning Committee

Stakeholders Endorse Expanded Dual Fuel Manual Definition

The Planning Committee endorsed by acclamation manual revisions to reflect FERC’s granting of a PJM proposal to expand the definition of dual fuel gas generation to include configurations where fuel is stored offsite but can be directly supplied by a dedicated pipeline (ER25-3413). (See “Reworked Dual-fuel Definition Endorsed,” PJM MRC/MC Briefs: July 23, 2025.)

The revisions to Manual 21B: PJM Rules and Procedures for Determination of Generating Capability require that dual fuel resources with off-site storage be “similarly situated and comparable to the existing classes of dual fuel gas-fired resources.”

Transmission Expansion Advisory Committee

Supplemental Projects

Dominion presented a need to replace 229 structures on four lines due to deterioration of bracing, crossarms and insulators. About 30.2 miles of steel towers and H-frames were installed in 1979 and serve 54 MW of load and 50 MW of solar capacity. The towers are along the Lanexa-Harmony Village 230-kV line and the Lanexa-Goalder’s Creek, Goalder’s Creek-Owl Trap and Owl Trap-Harmony Village 115-kV lines.

The utility presented a $35 million project to serve a 100-MW industrial load in Goochland County by constructing a 230-kV substation, named West Creek, along the Rockville-Short Pump 230-kV line. The double circuit line would be expanded by 6.5 miles to the new substation. The project is in the planning phase with a projected in-service date of July 26, 2028.

Dominion presented a $32 million project to serve a 300-MW data center in Culpeper County by constructing a 230-kV substation, named Shaw, along the Kyser-Remington line. The project is in the planning phase with a projected in-service date of May 1, 2028.

Dominion presented a $21 million project to serve a 176-MW data center in Louisa County with a new 230-kV substation, named Frances, adjacent to the Southall substation and connected by a new double circuit 230-kV line. The project is in the planning phase with a projected in-service date of Aug. 1, 2027.

A $12 million Dominion project would resolve a 300-MW load drop violation associated with the construction of the Frances substation by rebuilding 1.1 miles of the Southall-North Anna 230-kV line, which would pass through Frances, and expand North Anna with new 230-kV breakers at the line’s termination. The only alternative considered was a new 230-kV source from the Gordonsville substation 30 miles away. The project is in the planning phase with a projected in-service date of Dec. 30, 2028.

A $21 million project from Dominion would serve a 292-MW data center in Louisa County with a 230-kV new substation, named Wesbey Drive, adjacent to the Foxbrook Lane substation. It is in the planning phase with a March 1, 2029, in-service date.

FirstEnergy presented a need in the JCPL zone to address the possibility of the Manchester substation being forced offline if the Cookstown-Larrabee-Whitings 230-kV line is interrupted or there is a fault on a remote end breaker. The substation serves about 7,000 customers with 23 MW.

FERC Approves Generator Fines for Violations of ISO-NE Offer Rules

FERC has approved an agreement resolving an investigation into alleged violations by Berkshire Power Co. of ISO-NE energy offer rules. Tenaska Power Services, the parent company of Berkshire Power at the time of the violations, has agreed to pay a $51,000 penalty to the U.S. Treasury and $78,354 plus interest in disgorgement to ISO-NE (IN25-13).

The investigation concerned reductions to the dispatch requirement of Berkshire Power’s 251-MW gas generator in January 2021. The generator had a 229-MW capacity supply obligation (CSO) at the time. FERC’s Office of Enforcement and Regulatory Accounting concluded Tenaska violated the ISO-NE tariff “by modifying the real-time offers of the Berkshire Generator based on economic factors rather than physical availability.”

Under the rules of ISO-NE’s capacity market, resources with CSOs must offer into the day-ahead and real-time energy markets an amount of power that meets or exceeds their CSOs. Resources can reduce their offer requirements only to account for physical — not economic — limits.

According to the stipulation of facts under the Jan. 12 consent agreement, the generator could have procured enough gas to operate at its 251-MW economic maximum, though it would have had to pay a higher price for the gas than it anticipated when it made its day-ahead offer for Jan. 11, 2021. Berkshire Power asked ISO-NE to reduce the maximum dispatch of the generator to 150 MW, failing to disclose that the unit did not have a physical limit.

The Office of Enforcement “determined that attempts to reduce the dispatched level of the Berkshire Generator resource falsely and misleadingly communicated to ISO-NE a physical inability to operate at the resource’s CSO,” adding that “such a reduction was not due to a physical inability to operate but rather an economic decision not to procure higher-priced fuel.”

FERC ruled that the agreement between Tenaska and the Office of Enforcement “is a fair and equitable resolution of the matters concerned and is in the public interest, as it reflects the nature and seriousness of the conduct and recognizes the specific considerations stated above and in the agreement.”

UCS: Climate Change Induced Worst MISO Outages of the Decade

The Union of Concerned Scientists said MISO’s most devastating power outages in the past decade can be attributed to an increasingly unstable climate and compounding weather events.

UCS published a new analysis naming climate change as the culprit behind the 10 most severe blackouts in the footprint since 2014. The nonprofit science advocacy organization said all of the 10 largest power outage events over the decade have occurred since 2020, with half occurring in 2020 itself. UCS said each incident in the top 10 lasted multiple days and was associated with “compound weather events occurring over a large geographic region.”

UCS defined the worst power outages as the “greatest number of customers without power on a single day.” Outages varied from 800,000 to 1.6 million customers without power across the MISO footprint.

UCS said MISO and its membership should be girding the grid to withstand extreme weather and warned that a lack of preparedness will spell more outages for more customers.

Across MISO, top spots were claimed by derechos across the Midwest: two in 2020 and one in 2021. On June 11, 2020, the remnants of Tropical Storm Cristobal joined with a low-pressure system over the Great Lakes to produce maximum 75 mph wind gusts and several tornadoes. Two months later, another derecho that wrought $11 billion in damage cut power to parts of South Dakota, Nebraska, Iowa, Illinois, Wisconsin, Indiana, Michigan and Ohio. This time, winds reached 100 mph, and the storm spawned 26 weak tornadoes.

Days later, MISO’s Gulf of Mexico weathered Hurricane Laura on Aug. 27, 2020, which made landfall as a Category 4 in coastal Louisiana. Extensive flooding and wind damage in coastal Louisiana and Texas accounted for much of the hurricane’s $19 billion in damage.

Weeks later, Hurricanes Delta and Zeta followed on Oct. 10, 2020, and Oct. 29, 2020, respectively. The two followed an almost identical point of entry in Louisiana. Delta spawned far-flung tornadoes and brought more flooding to already inundated drainage systems in eastern Texas, southern and central Louisiana, and portions of Mississippi and Arkansas. It caused $2.9 billion in damage. Zeta’s higher winds caused $3.9 billion in damage to the grid.

“In the 10 worst outage events reviewed, it is never merely a severe thunderstorm or a hurricane alone that leads to these extensive outages. Rather, it is a derecho with multiple tornadoes and wildfires. Or it is a hurricane with tornadoes, coastal and inland flooding, follow-on fires, and extreme heat or damaged industrial facilities causing the accidental release of toxins,” UCS wrote in the new analysis.

To submit a commentary on this topic, email forum@rtoinsider.com.

The group noted that nearly all the most acute outages were linked to high winds, though floods, fire and ice also damaged the system.

“Where high winds dominate, damage to the grid results either from trees falling on power and transmission lines or from winds directly bringing down poles and lines,” UCS wrote. The nonprofit said repair and replacement of wind-damaged lines “may be among the biggest factors driving recent increases in electricity prices,” a little-reported detail.

Outages following summertime derechos in 2020 and 2021 | UCS

“Sequential storms like back-to-back Hurricanes Laura, Delta and Zeta in 2020 pose another type of challenge, leaving hardly any time for communities to recover between events,” UCS wrote. “As grid-damaging storms occur more frequently, areas that have experienced damages have little time to rebuild before the next extreme event and therefore are more vulnerable to deeper losses. … This means that people’s homes have been covered only by tarps, not solid, new roofs; water-damaged structures have not yet dried out; and dunes have not re-formed, allowing coastal surges to reach deeper inland.”

UCS said the repeated bouts of severe weather mean poles and power lines have barely been stood back up or restrung when they’re vulnerable to severe weather again.

In early August 2021, another derecho targeted the MISO footprint, this time bringing hurricane-force winds and flash flooding to a nearly 800-mile stretch from southeastern South Dakota and northeastern Nebraska through Iowa and on to northern Illinois, southern Wisconsin, northern Indiana, southern Michigan and western Ohio. The long line of thunderstorms caused an estimated $11.5 billion in destruction.

By the end of August 2021, Hurricane Ida — another Category 4 — followed a familiar path up Louisiana, generated at least 35 tornadoes and caused $75 billion in damage ($55 billion in Louisiana alone). Individual power outages lasted for more than a month in some cases, and some of the nearly 90 deaths attributable to the storm were due to a lack of air conditioning.

To round out 2021, on Dec. 16, uncharacteristic thunderstorms targeted Minnesota, Iowa and Nebraska with high winds. Minnesota reportedly logged its first-ever tornado in December.

UCS completed its list with severe thunderstorms that formed across southern Michigan in late August 2022 and a punishing, dayslong winter storm in late February 2023 that delivered ice, wind and heavy snow across several states.

“Extreme weather events can no longer be shrugged away as acts of God or system anomalies that we have no power to foresee or plan for,” report lead author Rachel Licker said in a press release. “Many parts of the central United States are projected to experience increases in severe thunderstorms, including derechos and hailstorms, and greater rainfall from hurricanes that make landfall. Some parts of the region may see more intense snowstorms, as well. Policymakers need to increase the electricity grid’s resilience to worsening climate change-fueled extreme weather or people will lose electricity, heat and air conditioning when they need it most. Failure to act is negligence that some could pay for with their lives.”

Report co-author Susanne Moser said it’s clear extreme storms supercharged by a warming climate are driving serious outages.

“As grid-damaging storms occur more frequently, areas directly affected have little time to rebuild before the next extreme weather event and end up spiraling into deeper and deeper vulnerability. Understanding the risks this poses for the electricity grid — and investing in the grid to mitigate those risks — is a question of safety for people and their families,” Moser said.

Canada’s Emission Reductions Dependent on Fixing Industrial Carbon Markets

After scrapping most Trudeau-era climate policies, Prime Minister Mark Carney hopes to tighten rules over Canada’s industrial carbon markets, which observers say have failed to incentivize emission reductions.

Since replacing Justin Trudeau in March 2025, Carney has eliminated a controversial carbon tax on consumer fuels, suspended a requirement that electric vehicles make up an increasing share of car sales and backed off on a phaseout of gas-fired generating plants.

As a result, the nation’s emissions trajectory is largely dependent on industrial carbon markets created under federal legislation in 2018 and now the subject of a scheduled review.

The Ministry of Environment and Climate Change in December issued a discussion paper seeking feedback on the federal “benchmark” — the national stringency standard all provincial and territorial systems must meet — which covers more than one-third of Canada’s total emissions, including the oil and gas industry and electric generation.

The government said its engagement seeks to ensure that industrial pricing “provides the necessary incentives and framework to drive decarbonization, clean technology investment and competitiveness.” Comments are due Jan. 30 via email to tarificationducarbone-carbonpricing@ec.gc.ca.

Alberta Agreement

The discussion paper acknowledges complaints by industry that the existing system is inefficient and is hurting their competitiveness. It also follows Carney’s Nov. 27 Memorandum of Understanding with Alberta Premier Danielle Smith, in which the federal government made numerous climate concessions, including the suspension of federal Clean Electricity Regulations, which would have required provinces to start phasing out gas-powered generating plants lacking carbon capture in 2035.

Although the electricity rules are being lifted only in Alberta — the nation’s largest greenhouse gas emitter — it “surely opens the door to doing likewise for other provinces that have chafed at it,” wrote Globe and Mail columnist Adam Radwanski.

The concessions prompted Steven Guilbeault — formerly Trudeau’s environment minister — to resign from Carney’s Liberal cabinet. But some climate activists said they were cheered by Alberta’s agreement to work with the federal government to raise the price of credits in the province’s oversupplied industrial carbon market — now trading below $20/metric ton (Mt) — to a “headline” price of $130/Mt.

Facilities with compliance obligations must pay the headline price or submit credits. A $130/Mt headline price would create incentives for heavy emitters to invest in climate capture and other green technologies, said Michael Bernstein, CEO of climate policy group Clean Prosperity.

“This agreement is a sign that we could finally be moving beyond the long-running disagreements between Ottawa and the provinces over climate policy, and charting a pragmatic path to achieve our climate goals while also strengthening Canada’s economy,” he said.

To submit a commentary on this topic, email forum@rtoinsider.com.

Provinces Falling Short

Seven of Canada’s provinces, including Alberta and Ontario, use provincial output-based pricing systems (OBPS), while four use a similar federal system.

OBPS set performance standards defined as emissions per unit of production. Companies whose production is better than the standard generate credits they can sell; those that cannot meet the standard either buy credits or pay the headline carbon price on excess emissions.

Designed correctly, says the Canadian Climate Institute, such systems can incentivize emission reductions with low overall costs and little incentive to shift production to jurisdictions without carbon limits.

But the institute and others say some current markets are not working because they are oversupplied with credits. While the 2025 headline price was $95/Mt — scheduled to rise to $170/Mt in 2030 — emitters can purchase credits at a fraction of that cost in Alberta and elsewhere.

Clear Blue Markets, which provides consulting and market research on carbon markets, said provincial markets are falling short, citing a lack of price transparency, Alberta’s freeze on its carbon price and oversupply risks in British Columbia and Quebec.

Alberta’s freezing of its headline price and its surplus of 48 million credits have pushed trading prices to about $18/Mt, the consulting firm said in late November. Prices in federal OBPS, including Manitoba and Prince Edward Island, have been depressed to $37.50 by the inflow of cheap “offsets” from Alberta, it said.

“Ontario’s [Emissions Performance Standards program] remains robust, supporting a strong credit market. However, its 2024 funding mechanism, tying proceeds to emissions paid rather than performance, may weaken the emissions reduction signal,” Clear Blue Markets said.

Climate advocates say the program also needs a financial mechanism to establish a price floor on credits, as would be established at $130/Mt under the MOU with Alberta.

“To turn this MOU into shovels in the ground, that financial mechanism should take the form of carbon contracts for difference offered jointly by the federal and Alberta governments,” Bernstein said. “These contracts are the insurance policy that will de-risk tens of billions in low-carbon investment by giving investors confidence in the durability of industrial carbon pricing.”

“If governments uphold their commitments to strong carbon markets, the contracts need never be exercised, and so cost nothing to taxpayers,” Clean Prosperity said.

Industry Complaints

In 2024, industry organizations including Canadian Manufacturers & Exporters, the Canadian Renewable Energy Association, the Canadian Steel Producers Association, the Cement Association of Canada and the Chemistry Industry Association of Canada sent an open letter to Canada’s provincial environment ministers complaining of a “disconnect” among the nation’s provincial and territorial carbon markets that they said was hurting economic growth and decarbonization.

The group said it supports industrial carbon markets as “the most flexible and cost-effective way to incentivize industry to systematically reduce emissions.”

But it said “a patchwork of provincial carbon pricing systems has produced numerous barriers and created significant red tape across efforts to decarbonize.”

The group called for more transparency in credit markets and for removing rules that prevent industry from buying and selling carbon credits across provincial borders.

It also asked for “high-integrity offset protocols” to ensure emissions reductions are “permanent, additional and verifiable” and that provinces should invest 100% of industrial carbon pricing revenues into industry to accelerate decarbonization.

It also sought actions to support vulnerable sectors and prevent carbon leakage to jurisdictions with less stringent climate policies, citing the EU’s Carbon Border Adjustment Mechanism, a tariff on imports of carbon-intensive products such as steel, cement and electricity.

Costs

In a 2023 study on the impact of the carbon pricing on Ontario, the Canadian Energy Centre predicted it would increase costs almost 11.8% for the province’s electric generation, transmission and distribution sector.

The study said carbon pricing would fall most heavily on the province’s iron and steel manufacturing sector — with a 62% increase — due to its use of coke and coal. Basic chemicals, pesticides and fertilizers were projected to jump 29.5%.

“The carbon tax will have the most significant impact on those industries in the manufacturing sector that have a high trade exposure and a low profit margin,” said CEC. The group’s goal is to make Canada “the supplier of choice for the world’s growing demand for responsibly produced energy.”

Three Options

Existing mandatory carbon pricing systems are believed to cover 595 facilities and 252 Mt of CO2 annually (36% of Canada’s emissions). Including voluntary facilities, existing carbon pricing systems are estimated to cover 274-281 Mt of emissions (39-40%).

The ministry said it is considering three options for determining what emitters will be covered by carbon regulations: The “threshold-based” option would cover all industrial and manufacturing facilities emitting above 10,000 (Option 1A) or 25,000 Mt (Option 1B) annually (264-273 Mt; 38-39%).

Option 2, an “activity-based” approach, seeks to cover all facilities in an industry to avoid providing a competitive advantage to smaller facilities. The ministry proposed covering oil and gas, mining, chemicals, fertilizers and other manufacturing — including steel and cement — that emit at least 10,000 Mt annually (278 Mt; 40%).

Option 3, which combines the threshold- and activity-based approaches, would be the “most effective” at incentivizing emission reductions, the ministry said (284 Mt; 41%.)

All three options would apply to fossil-fueled electric generation.

The government’s engagement to improve carbon markets design and price signals means that “meeting the federal benchmark will increasingly require jurisdictions to demonstrate that their systems function as effective markets and not simply that they comply on paper,” said Sussex Capital. “While provinces and territories will retain flexibility over design, the federal government is signaling higher expectations around durable price signals, healthy credit markets and demonstrable investment impacts.”

The MOU requires Alberta and the federal government to reach an agreement on the $130/Mt price by April 1.

“How this shakes out could determine whether an agreement to work together on policy and potential pipeline approval scuppers Canadian climate action, or whether it evolves into a better, more broadly supported effort to combat global warming,” wrote the Toronto Star’s Alex Ballingall.

NYISO Stakeholders Request Cluster Study Enhancements

The NYISO Transmission Planning Advisory Subcommittee (TPAS) discussed stakeholder comments on possible improvements to the cluster study process and the system deliverability test process in response to presentations given in December 2025.

Stakeholders including the Alliance for Clean Energy New York and Granite Source Power asked for improvements to the pre-application process and increased training for interconnection customers. ACE NY asked for clarification to NYISO’s definition of “physical infeasibility” and for more information to be given to interconnection customers once a project is deemed infeasible. The organization asked NYISO to require that transmission owners provide interconnection customers with the studies that determined whether a project is infeasible.

GSP asked for greater standardization between transmission owners regarding site plan requirements and agreed with ACE NY that the physical infeasibility screening needed clarification.

RWE Clean Energy asked for a fast-track interconnection process for projects addressing reliability issues. Invenergy asked for an expedited capacity resource interconnection study mechanism for interconnection of co-located energy storage resources.

NYISO staff said in an earlier presentation that managing the reliability impact of the 70 GW of new generation in the queue requires numerous upgrades. The ISO previously stated that the first cluster study — the “transition cluster study” — had posed challenges to staff including many iterations of deficiency reviews due to inconsistent and inaccurate interconnection requests. The deficiencies led to withdrawals, which led to dispute resolution processes and model updates. The large volume of projects in the cluster study also poses significant challenges for validating interconnection requests and performing required evaluations on time.

The ISO presentation indicated it also wanted to pursue increased training for interconnection customers, simplify paperwork for interconnection requests and clarify the deficiency process.

Deliverability Test Recommendations

The deliverability test is a critical part of the interconnection process, which helps determine if a project is deliverable at its requested “capacity resource integration service” level, measured in megawatts. If a project cannot deliver, NYISO looks for system deliverability upgrades — upgrades to the grid — that would allow the project to function at its requested megawatt value and determines costs to the resource.

NYISO identified challenges with the deliverability test, particularly the establishment of a base case and unforced capacity factor assumptions in late 2025. Stakeholders submitted comments for discussion at the Jan. 5 TPAS meeting.

ACE NY asked for clarification of the implementation schedule of the updates to the deliverability test, citing possible confusion over when the new test would be in place. It added there was a risk of confusion with system deliverability upgrade cost estimates and asked NYISO to issue two separate ones based on the proposed new rules and the old rules.

The Market Monitoring Unit issued a memorandum in response to NYISO’s move to reform the deliverability test. The MMU has long argued that the current test penalizes new resources and is poorly suited to new technologies seeking to interconnect, specifically storage resources. The MMU asked NYISO to consider creating more capacity zones, reflect import bottlenecks in capacity accreditation factors and remove “highways deliverability test” from the cluster study.

Tony Abate, representing the New York Power Authority, said he didn’t think the MMU’s suggestions were possible to implement while the ISO is trying to reform the cluster study process. He said he appreciated the MMU’s “aspirational” stance but didn’t think new capacity zones could be delivered simultaneously with the other reforms.

Thinh Nguyen, senior manager of interconnection projects for NYISO, said the ISO is still in the process of reviewing comments and would get back to stakeholders at a future meeting.

In Other Business

TPAS heard system impact study scopes for two data center projects, both being developed by Turn Management in Herkimer County. Collectively, the two data center loads would be 500 MW on the same site. TPAS did not issue any objections and allowed both SIS scopes to move forward for Operating Committee consideration.

MISO Picks AEP, Berkshire’s Joint Venture to Build $1.2B 765-kV Line

MISO has selected a 50/50 joint venture between Transource and Berkshire Hathaway Energy Transmission to build a $1.2 billion, 765-kV project from the RTO’s second long-range transmission portfolio.

MISO opted for the jointly owned Midcontinent Grid Solutions to build the nearly 200-mile Bell Center-Columbia–Sugar Creek–IL/WI State Line (BECI) 765-kV competitive transmission project.

“Transource demonstrated the most 765-kV capabilities of all developers, and it will partner with a strong contractor to operate and maintain the project after it is complete,” MISO said in its Jan. 6 selection report. The companies’ joint enterprise outperformed four other unnamed bidders, according to MISO.

It said Midcontinent Grid Solutions “demonstrated reasonable cost estimates and offered reasonable cost containment,” though it didn’t propose the lowest revenue requirement, which ranged from $533 million to a little more than $1 billion among bidders. Midcontinent Grid Solutions pinned its revenue requirement between $775 million and $790 million.

BECI is part of MISO’s second, $22 billion long-range transmission plan portfolio, approved by the MISO Board of Directors at the end of 2024. Most of the portfolio is composed of 765-kV projects.

BECI facility map | MISO

Midcontinent Grid Solutions pledged to cap its annual revenues through the end of the 14th year of the project’s existence at its estimates. It said it would not recover any revenue beyond its caps unless it was necessary for the company to earn a minimum 8.5% return on equity.

Estimated capital costs among the bidders varied from $808 million to $1.29 billion. Midcontinent’s winning bid predicted it would need a little more than $1 billion. MISO estimated the project would cost $1.2 billion.

American Electric Power owns 86.5% of Transource; Evergy owns the remaining 13.5%. To date, AEP has constructed and operates more than 2,000 miles of 765-kV lines.

MISO’s selection focused on developers’ design integrity and plans for maintenance once the lines are in service, design flexibility, ability to coordinate with other interconnecting transmission owners, and capability to finance and manage a large project.

MISO said Midcontinent Grid Solutions’ guyed, y-shaped lattice designs were the lightest structures put forward for consideration. The grid operator noted that lighter structures make helicopter installation easier while still designed to withstand a 300-year mean recurrence interval weather event. MISO noted that the company plans to keep at least 22 of the 765-kV structures on hand to make major repairs if necessary.

However, MISO said a weak point in Midcontinent’s proposal may lie in is its plan for sourcing construction materials and its routing. The RTO said the company’s “planned procurement responsibilities are less clear than other developers,” and its plan “demonstrates less certainty than other developers regarding its planned vendors and suppliers by not providing any letters of support and instead discussing supplier relationships, forecasted demand and capacity reservations which show that there is sufficient production capacity for BECI.”

MISO similarly said the company’s routing lacked specificity and was silent on whether it would route in accordance with Wisconsin’s siting priorities. It also didn’t appear to fully flesh out the complexities of siting near wetlands, forested areas and an airport, MISO said.

Transource said it has yet to draw a final route for the project.

MISO expects the line to be in service by June 1, 2034, pending regulatory approval.

Relatedly, MISO announced it would rely on Chicago-based Viridon Midcontinent to build a 345-kV project, also stemming from the second long-range portfolio. The smaller, $350 million project will span about 105 miles in southeast Wisconsin. MISO expects the line to be energized by June 1, 2033.

Blackstone Energy Transition Partners, one of Blackstone’s private equity funds, owns Viridon.

MISO said it’s concerned Viridon may have underestimated the capital costs of the project in its bid. Three other bidders estimated the project would cost anywhere from $471 million to $481 million; MISO itself estimated the project would cost $662 million to complete.

However, MISO said its confidence in its selected developer was buoyed by the fact that Viridon already executed an agreement with an experienced general contractor and proposed “cost containment strong enough to likely ensure the lowest cost to the ratepayer even if its estimated costs rose significantly.”

NYISO Presents Final LCRs for 2026/27

NYISO has presented the final locational minimum installed capacity requirements for the 2026/27 capability year. The LCRs, expressed as a percentage of peak load forecast, represent the minimum capacity that generators and load-serving entities must maintain within the downstate zones. These zones have substantial transmission constraints.

Based on the 24.5% installed reserve margin set by the New York State Reliability Council, NYISO determined the minimum LCR for New York City, Long Island and the Lower Hudson Valley to be 86.4%, 110.3% and 82.5% respectively, assuming the Champlain Hudson Power Express is online. If CHPE is not online, NYC would have an LCR of 82.6%. The other zones’ LCRs remained unchanged.

2026/27 Informational Capacity Accreditation Factors

At the Jan. 6 Installed Capacity Working Group meeting, NYISO also presented capacity accreditation factors for the upcoming capability year for stakeholder informational purposes. These are not the final CAFs that will determine the market revenue of suppliers for the capability year. Final CAFs are due March 1.

Unlike in previous years, NYISO included two sets of informational CAFs, one calculated with CHPE in and one without. The largest shift in informational CAFs occurs in the “non-firm” resource class. These are fossil fuel resources without contractual commitments from fuel suppliers. If CHPE is included in non-firm, generators are rated at 55.32% and 58.99% in the New York City suburbs and New York City respectively. If CHPE does not come in, these values climb to 84.67% and 85.77% respectively. The full table of results can be found here.

NYISO said CHPE’s impact on non-firm generator informational CAFs was driven by increased loss of load expectation events between the CHPE-in and CHPE-out scenarios. CHPE is modeled as a summer-only resource, so when CHPE is “in” it increases winter risk by being assumed to be unavailable. Non-firm generators have opted not to declare that they have secured fuel for the winter capability period, which means they are worth less in situations where winter risk is elevated.

PJM Presents 1st Look at Co-located Load Compliance Filings

PJM presented stakeholders with an initial look into the first of a handful of FERC compliance filings it is drafting to define how co-located large loads receive transmission service (EL25-49).

The first compliance filing, which is due by Jan. 20, will focus on the most straightforward directives FERC included in its order: revising the tariff to explain how developers seeking to pair large loads with dedicated supply can receive provisional interconnection service, specify how resources may interconnect to provide less than its nameplate rating to PJM, accelerate interconnection and use surplus interconnection service to bring resources online faster.

PJM is required to submit an informational report on the proposals in the Critical Issue Fast Path (CIFP) process focused on large-load interconnections. The commission specifically asked for details on proposals to expedite generation interconnection, changes to the reliability backstop that could allow it to respond to resource adequacy shortfalls, and changes to PJM’s load forecasting and demand flexibility rules.

PJM Associate General Counsel Mark Stanisz said PJM intends to keep the tariff language it is developing under the compliance filing aligned with the market design proposals the Board of Managers is considering under the CIFP process. He presented the proposal to a Co-Located Load Order Workshop on Jan. 9.

“There’s a lot in the air, but we are monitoring it all and are trying to proceed in a coherent way,” he said.

New resources intended to exclusively serve co-located load would be permitted to skip to the final agreement negotiation phase of the interconnection process if it is determined no network upgrades would be required.

PJM Vice President of Planning Jason Connell said new resources would be able to sidestep the interconnection queue only if they would be unable to inject energy into PJM’s grid, such as by tripping offline if the customer they were serving was interrupted. He compared the interconnection of co-located generation to the RTO’s rules for behind-the-meter generation (BTMG), which are not required to go through the queue. Projects already in the queue would not be able to use the new pathways.

New resources that do require network upgrades could use provisional interconnection service to begin partial operations serving the co-located load while those upgrades are under construction.

Developers of co-located resources would be permitted to provide less than the full nameplate to PJM but would be limited to reducing its interconnection service only by the amount needed to serve the paired customer.

Stanisz said the first round of directives the commission gave is more prescriptive than the rest of the order and PJM is looking at governing document language it needs to modify. Staff are reviewing draft tariff changes with the intention of posting language within a few workdays. The first compliance filing may include a definition of co-location — a change the commission requested but did not specify which compliance filing it should be included in.

Manager of Stakeholder Process and Engagement Michele Greening said a survey will be posted along with the proposed tariff revisions to solicit stakeholder feedback.

“It’s all in the spirit of clarification and frankly in the most surgical of ways,” Stanisz said of the directive for the initial filing.

In the second compliance filing, due Feb. 17, PJM is tasked with adding three new forms of transmission service that can be used to serve co-located load, requiring the customers be charged for regulation and black start service based on their gross load, clarifying how the network upgrades required to serve co-locations will be studied, and requiring that existing interconnection customers pay for those upgrades. The filing is due by Feb. 17.

Stanisz said the commission’s order did not comprehensively address many of the jurisdictional issues around the interconnection of large loads and how they receive grid service. The commission’s assertion of jurisdiction over generation interconnections is not novel or trailblazing, so unanswered questions about its jurisdiction over large load interconnections are more likely to be addressed in the Advance Notice of Proposed Rulemaking (ANOPR) on large load interconnections.

Asked if PJM is considering requesting a rehearsing, extension or clarification of the order, Stanisz said staff are focused on preparing the deliverable compliance directives the commission has requested. While other entities might seek such relief, and PJM would review those requests, at this time he is not aware of any intent for the RTO to make such filings.