Power & Pipes

In October 2026, FERC’s Office of Electric Reliability, Division of Cyber Security released its annual Lessons Learned from Commission-Led CIP Reliability Audits summarizing findings from audits conducted during fiscal year 2026. Registered entities should assess their internal compliance programs in light of the trends and issues identified by FERC in preparation for future Critical Infrastructure Protection (CIP) audits, as the issues highlighted in these reports are often covered during audits.  The report highlights compliance with CIP 002-5.1a as a priority for FERC, including registration for new resources, properly accounting for functions performed by third parties, and using AI in a protected environment.

 

Carbon markets are often discussed without regard to geographic or jurisdictional compliance boundaries, implying that emissions in one location can universally be offset through a credit or allowance issued in another location. While that may be the case in the context of global voluntary carbon market transactions, compliance markets are fragmented by geography, regulated sector, and the rules governing which instruments can be used for compliance. Thin or isolated markets can make price discovery harder and leave companies with fewer ways to manage compliance costs.

On August 26, US President Trump issued an executive order declaring a national emergency regarding risks associated with foreign-produced equipment used in the US bulk-power system. The order cites potential cyber, remote access, sabotage, and supply disruption risks, noting that growing electricity demand increases the consequences of potential attacks on the electric grid.

Efforts to develop a global carbon market are often discussed in terms of climate science, project methodologies, and carbon pricing. However, the creation of a functioning international market is, to a significant extent, a legal undertaking. Kenya’s recently released carbon-market rulebook illustrates why regulatory development is necessary—and how changes in the rules can materially affect developers, financiers and carbon-credit purchasers.

Recent geopolitical tensions involving Iran have once again exposed one of the aviation industry's most enduring vulnerabilities: its dependence on conventional jet fuel. Although airlines have long operated in an environment characterized by fluctuating oil prices, the latest instability in the Middle East serves as a reminder that the mere prospect of disruptions to global energy supplies can send shockwaves through fuel markets. For an industry in which fuel routinely represents one of the largest operating expenses, price volatility is more than a financial inconvenience—it is a strategic risk.

On June 18, 2026, the Federal Energy Regulatory Commission (FERC) directed each of the six regional grid operators it regulates (the Independent System Operators (ISOs) and Regional Transmission Organizations (RTOs)) and their member transmission owners to justify or reform the terms of their tariffs related to interconnections for data center and other large energy users (Show Cause Orders).

The North American Electric Reliability Corporation’s (NERC’s) new Reliability Guideline, Risk Mitigation for Emerging Large Loads, provides a detailed framework for addressing reliability risks associated with rapidly growing large loads, including data centers, cryptocurrency mining facilities, hydrogen production facilities, manufacturing facilities, and arc furnaces.

The North American Electric Reliability Corporation (NERC) has issued a Level 3 Alert, the highest possible severity level and one that is rarely used by NERC, requiring the immediate attention of many NERC registered entities. While the Alert is not itself a new Reliability Standard, it directs certain registered entities to assess and report on proposed changes to modeling, studies, protection, and communications practices for large computational loads.

In the last 10 years, annual electric vehicle (EV) sales in the US have increased by nearly 1,100%. While approximately 115,000 new EVs were sold in US markets in 2015, calendar year 2025 sales were substantially larger—nearly 1.3 million new EVs were sold in US markets. Despite strong sales numbers, the state of the EV industry in the US at the conclusion of 2025 could best be described as one of confusion. As sales numbers increased year over year, changes in various federal policy initiatives signaled potential trouble ahead for the EV market. 2025 concluded with a shifting tide in public perception about the state of the US EV market as some media narratives forecast a crash of the industry.

FERC’s Office of Enforcement and Regulatory Accounting (Enforcement) has released its annual report on enforcement actions during fiscal year 2025, which ran from October 1, 2024 to September 30, 2025. The report provides a comprehensive overview of Enforcement’s activities across the electric, natural gas, and oil pipeline industries.