Summaries of the agenda items for the Federal Energy Regulatory Commission's monthly open meeting to be held on November 20, 2025, pursuant to the sunshine notice released on November 13, 2025.

E-1 – System Energy Resources (Docket No. ER25-2258-001). On May 19, 2025, System Energy Resources (SERI) filed proposed amendments to the effective Unit Power Sales Agreement (UPSA) on file with the Commission. SERI owns or leases 90 percent of Grand Gulf Nuclear Station, a generating facility located in Mississippi, and makes capacity and energy sales to four of its affiliated public utilities as part of Entergy Services, LLC. Namely, SERI sought to revise entitlement percentages under the wholesale rate schedule, pursuant to a settlement approved by the Commission in November 2024, for Entergy Mississippi, Entergy New Orleans, Entergy Arkansas, and Entergy Louisiana. Additionally, Entergy Louisiana would be removed as a party to the UPSA (and its entitlement reduced to zero percent). On June 9, 2025, the Arkansas Public Service Commission (APSC) submitted a protest, contending that SERI did not sufficiently demonstrate that the proposed revised UPSA entitlement percentages would be just and reasonable in accordance with Section 205 of the Federal Power Act (FPA) and that SERI did not show that the proposed revisions would be consistent with the public interest. On June 9, 2025, the Louisiana Public Service Commission (LPSC) filed comments in support of the proposed revisions to entitlement percentages. On July 31, 2025, the Commission issued an order accepting the revised UPSA, finding that the revised entitlement percentages based on their life-of-unit purchases are just and reasonable. On September 2, 2025, APSC filed a request for rehearing of the July 31 order. Agenda item E-1 may be an order on the rehearing request.

E-2 – System Energy Resources (Docket No. ER22-24-002). On October 1, 2021, SERI filed proposed changes to the effective UPSA, pursuant to Section 205 of the FPA, in order to allow for the inclusion of prepaid and accrued pension costs in rate base associated with its qualified pension plans. In the filing, SERI stated that the inputs for the proposed pension changes originate from the qualified pension plan data contained in its annual FERC Form 1 filings as supplemented by certain accounting records. On October 22, 2021 and November 2, 2021, respectively, LPSC submitted a protest and supplemental protest, asserting that the actuarial approach proposed by SERI in order to calculate the "prepaid" pension expense is faulty and that SERI relied on misleading representations in its proposal. LPSC also stated that SERI did not furnish the appropriate data that would aid the Commission in evaluating the prepaid or accrued pension costs. On November 23, 2021, SERI filed an answer to the LPSC protests, stating that LPSC offered factually incorrect or irrelevant assertions to the calculation of prepaid pension costs. On March 15, 2022, the Commission issued an order accepting and suspending for a period the proposed revisions, subject to refund, and establishing settlement judge procedures. Over the ensuing months, an administrative law judge (ALJ) presided over seven settlement proceedings among the parties. On August 7, 2023, the chief judge issued an order terminating the settlement proceedings, and designated a presiding judge to preside over a final hearing and subsequently issue an Initial Decision on the outstanding material issues. On September 6, 2023, a prehearing conference between the parties was held. On October 16, 2023, SERI filed a partial settlement to resolve whether it had properly classified accumulated deferred income tax in the calculation of prepaid pension cost under the Commission's Uniform System of Accounts. The Commission approved the partial settlement as uncontested on January 18, 2024. On May 21, 2024, the parties commenced the hearing, which concluded on May 31, 2024. A post-hearing conference was subsequently held on June 12, 2024. On September 6, 2024, the chief judge issued the Initial Decision, finding that the "preponderance of substantial evidence" in the hearing record supported the proposition that the Commission should approve the proposed FPA Section 205 amendment to the UPSA and its embedded formula rate to include a line item for prepaid (i.e., accrued) pension cost in rate base. On October 7, 2024, the parties submitted respective Briefs on Exceptions with respect to the Initial Decision; on October 28, 2024, the parties submitted respective Briefs Opposing Exceptions. Agenda item E-2 may be an order on the Initial Decision and outstanding material issues.

E-3 – Pacific Gas and Electric Company (Docket No. ER24-3032-000). On September 13, 2024, Pacific Gas and Electric Company (PG&E) submitted a compliance filing, pursuant to Order No. 2023 and Order No. 2023-A, with respect to proposed amendments to its Wholesale Distribution Tariff (WDT). The PG&E WDT describes the terms under which PG&E provides open access to its distribution system to wholesale customers seeking to interconnect wholesale generation facilities. Order No. 2023, issued by the Commission on July 28, 2023, reformed the generator interconnection study processes of public utility transmission providers operating under effective OATTs. Primarily, Order No. 2023 required that transmission providers employ a first-ready, first-served cluster study process for large generating facilities exceeding 20 MW. Order No. 2023-A, issued on March 21, 2024, extended the compliance deadline to May 16, 2024. The Commission did not find that Order No. 2023 fully applied to WDTs but nonetheless directed PG&E and distribution system providers to "address its concerns and applicability in its individual compliance filing," due within 90 calendar days of the Order No. 2023 compliance filings of the relevant Regional Transmission Organization or Independent System Operator. In the compliance filing, PG&E stated that it has already incorporated many of the reforms set forth in Order No. 2023. Although it does not align precisely with all of the reforms proposed by the California Independent System Operator Corporation (CAISO), PG&E stated that it generally fashioned its compliance filing based on the form and structure of the CAISO Order No. 2023 compliance filing submitted on May 16, 2024. On October 4, 2024, California Energy Storage Alliance (CESA) filed a protest, contending that the PG&E compliance filing fails to provide interconnection customers with electric storage resources the ability to design and charge their facilities in a manner that would satisfy the proposed operating parameters. On October 15, 2024, PG&E filed an answer to the protest, stating that Order No. 2023 did not require utilities to use the proposed operating parameters or assumptions of an interconnection customer. Agenda item E-3 may be an order on the PG&E compliance filing.

E-4 – San Diego Gas & Electric Company (Docket No. ER10-1391-003). On August 28, 2024, San Diego Gas & Electric Company (SDG&E) submitted a compliance filing, pursuant to Order No. 2023 and Order No. 2023-A, with respect to proposed amendments to its Wholesale Distribution Access Tariff (WDAT). The SDG&E WDAT describes the terms under which SDG&E provides open access to its distribution system to wholesale customers seeking to interconnect wholesale generation facilities. Order No. 2023, issued by the Commission on July 28, 2023, reformed the generator interconnection study processes of public utility transmission providers operating under effective OATTs. Primarily, Order No. 2023 required that transmission providers employ a first-ready, first-served cluster study process for large generating facilities exceeding 20 MW. Order No. 2023-A, issued on March 21, 2024, extended the compliance deadline to May 16, 2024. The Commission did not find that Order No. 2023 fully applied to WDATs but nonetheless directed SDG&E and distribution system providers to "address its concerns and applicability in its individual compliance filing," due within 90 calendar days of the Order No. 2023 compliance filings of the relevant Regional Transmission Organization or Independent System Operator. Although it does not align precisely with all of the reforms proposed CAISO, SDG&E stated that it generally fashioned its compliance filing based on the form and structure of the CAISO Order No. 2023 compliance filing submitted on May 16, 2024. On September 18, 2024, CESA, Clean Energy Alliance and Community Power, and the Clean Coalition, respectively, filed protests of the SDG&E compliance filing, generally alleging that the proposed elimination of its Independent Study Process (ISP) for small generators would impede the ability of small generators to interconnect to SDG&E in a timely and efficient manner. Further, the protests echoed the concerns raised by CESA in the PG&E Order No. 2023 compliance proceeding discussed in agenda item E-3, namely that the operating assumptions for electric storage resources would fail to permit the control technologies that ensure operation within "agreed-upon parameters." On November 4, 2024, SDG&E submitted an answer to the respective protests, stating that it does not expressly prohibit certain practices (i.e., by removing the ISP but preserving the Fast Track serial screening process) in order to strike a balance "between preserving the interests of small and large generator interconnection customers." On August 1, 2025, San Diego Community Power, et al. submitted a motion for expedited consideration. Agenda item E-4 may be an order on the SDG&E compliance filing.

E-5 – Southern California Edison Company (Docket Nos. ER24-2776-000, ER24-2776-001). On August 14, 2024, Southern California Edison Company (SCE) submitted a compliance filing, pursuant to Order No. 2023 and Order No. 2023-A, with respect to proposed amendments to its WDAT. The SCE WDAT describes the terms under which SCE provides open access to its distribution system to wholesale customers seeking to interconnect wholesale generation facilities. Order No. 2023, issued by the Commission on July 28, 2023, reformed the generator interconnection study processes of public utility transmission providers operating under effective OATTs. Primarily, Order No. 2023 required that transmission providers employ a first-ready, first-served cluster study process for large generating facilities exceeding 20 MW. Order No. 2023-A, issued on March 21, 2024, extended the compliance deadline to May 16, 2024. The Commission did not find that Order No. 2023 fully applied to WDATs but nonetheless directed SCE and distribution system providers to "address its concerns and applicability in its individual compliance filing," due within 90 calendar days of the Order No. 2023 compliance filings of the relevant Regional Transmission Organization or Independent System Operator. Although it does not align precisely with all of the reforms proposed CAISO, SCE stated that it generally fashioned its compliance filing based on the form and structure of the CAISO Order No. 2023 compliance filing submitted on May 16, 2024. On September 4, 2024, Terra-Gen, LLC filed a protest, asserting that certain proposed deviations from pro forma provisions (namely, by failing to include the option for interconnection customers to provide operation assumptions) are neither consistent or superior to Commission requirements. On September 20, 2024, SCE filed an answer to the protest, stating that Order No. 2023 did not address operating assumptions for transmission or distribution service, and the assertion that SCE should be compelled to include at least one electric storage operating assumption would be assessed as part of the distribution service request, not interconnection service. Agenda item E-5 may be an order on the SCE compliance filing.

E-6 – EDF power solutions Development, Inc. (Docket No. EL25-111-000). On August 7, 2025, EDF power solutions Development, Inc. (EDF), on behalf of its subsidiary Rainbow Valley Energy Center, LLC, filed a petition for declaratory order, pursuant to Rule 207 of the Rules of Practice and Procedure of the Commission. EDF stated that, on November 7, 2023, Salt River Project Agricultural Improvement and Power District (SRP) submitted its new Large Generator Interconnection Process (LGIP) following the issuance of Order No. 2023. According to EDF, SRP failed to implement Order No. 2023 with respect to the affected system study process, which resulted in SRP removing Rainbow Valley from the interconnection queue. EDF stated that, "through no fault of Rainbow Valey and because of causes beyond its control," it had problems receiving certain affected system studies on a timely basis. On July 16, 2025, EDF sent a letter to SRP invoking dispute resolution processes and asserting force majeure under the SRP LGIP. On July 17, 2025, SRP notified EDF that it had withdrawn Rainbow Valley from the interconnection queue. On September 8, 2025, SRP filed a protest, stating that it had withdrawn its Safe Harbor status years prior, although it continues to provide reciprocal service to other transmission facilities. As such, SRP contends that because EDF itself does not offer transmission service by which SRP could reciprocate, the request is moot. On September 8, 2025, the American Public Power Association, Large Public Power Council, and National Rural Electric Cooperative Association also filed a protest, stating that the requested relief would contravene Commission precedent and that the Commission lacks statutory authority to issue such an order declaring that SRP's reciprocity tariff is no longer valid, as EDF sought. Agenda item E-6 may be an order on the petition.

M-1 – Duty of Candor (Docket No. RM22-20-000). On July 28, 2022, the Commission issued a Notice of Proposed Rulemaking (NOPR), pursuant to Sections 206, 215, 307, and 309 of the Federal Power Act (FPA), Sections 5, 14, and 16 of the Natural Gas Act (NGA), Sections 1(5)(a), 12(1)(a), 13, and 15 of the Interstate Commerce Act (ICA), Sections 311(c) and 501(a) of the Natural Gas Policy Act of 1978 (NGPA), and Sections 402(a)(2) and 402(h) of the Department of Energy Organization Act. In the NOPR, the Commission proposed to add a new section to 18 CFR part 1 to require that any entity communicating with the Commission or other specified organizations submit accurate and factual information, and to not submit false or misleading information, or to omit material information. The Commission stated that a "broadly applicable duty of candor" will improve its ability to effectively conduct oversight on the jurisdictional markets under its authority. A large number of stakeholders and interested parties submitted comments, including joint comments by certain RTOs including ISO New England (ISO-NE), Midcontinent System Operator, Inc. (MISO), PJM Interconnection, L.L.C. (PJM), and Southwest Power Pool, Inc. (SPP) on November 10, 2022. The joint RTO comments generally expressed support for the NOPR, stating that "it is important for the duty of candor to apply broadly to all information related to the administration of the RTO markets (including matters such as organizational structure, membership and credit matters)." Other comments, such as those filed by the American Public Power Association on November 10, 2022, expressed concern with respect to the "exceptionally broad" scope of the NOPR, and was particularly concerned as it would relate to communications with entities other than the Commission and its staff (i.e., if the NOPR were to apply to all communications with RTOs, ISOs, market monitors, the Electric Reliability Organization and its regional entities, and so forth). Agenda item M-1 may be an order furnishing a Final Rule on duty of candor.

M-2 – Waiver of Tariff Requirements (Docket No. PL20-7-000). On May 21, 2020, the Commission issued a Proposed Policy Statement to clarify requests for waiver of tariff provisions. The Commission stated that reviewing courts had instructed that "[t]he filed rate doctrine and the rule against retroactive ratemaking leave the Commission no discretion to waive the operation of a filed rate or to retroactively change or adjust a rate for good cause or for any other equitable considerations." Accordingly, the Commission determined that, under some circumstances, it has issued tariff waiver orders beyond the limits imposed by the filed rate doctrine. Under both Section 206 of the FPA and Section 5 of the NGA, the Commission is not permitted to allow retroactive changes to filed rates. A number of stakeholders and interested parties filed comments, generally offering feedback on exceptions to waivers of the prior notice requirement and other circumstances that do not violate the filed rate doctrine but continue to provide for some manner of flexibility. Agenda item M-2 may be an order on the Proposed Policy Statement.

G-1 – Supplemental Review of the Oil Pipeline Index Level (Docket No. RM25-2-000). On October 17, 2024, the Commission issued a Supplemental Notice of Proposed Rulemaking (Supplemental NOPR) proposing to amend the index level used to determine annual charges to oil pipeline rate ceilings in light of the decision issued in Liquid Energy Pipeline Association v. FERC by the U.S. Court of Appeals for the District of Columbia Circuit. The Commission proposed to use the Producer Price Index for Finished Goods (PPI-FG) minus 0.21 percent as the prospective index level for the remainder of the five-year period that began on July 1, 2021. A number of stakeholders and interested parties filed initial comments, with some concerns expressed about the frequency of the review (i.e., deviating from prior Commission policy to revise the Five-Year Index within four years). Certain parties raised the prospect of a destabilizing effect on regulated pipelines due to the potential implementation of new rates outside of the typical timeframe. On December 20, 2024, respectively, some parties filed reply comments, stating that the Supplemental NOPR would appropriately reinstate the oil pipeline index of PPI-FG minus 0.28 percent. Agenda item G-1 may be an order on the Supplemental NOPR.