FERC Order 881’s July 12, 2025 compliance date forces transmission policy leads to document ambient-adjusted rating tariffs, transparency commitments, and audit trails before regional reviews ramp up.
Executive briefing: Federal Energy Regulatory Commission Order No. 881 and companion Order No. 881-A require transmission providers to calculate ambient-adjusted line ratings (AARs) for near-term service and publish hourly ratings data by July 12, 2025. Regional transmission organisations must amend tariffs, coordinate with transmission owners on unique emergency ratings, and evidence stakeholder consultation consistent with Federal Power Act Sections 205 and 206. Compliance filings now under FERC and North American Electric Reliability Corporation (NERC) review make July a critical checkpoint for policy, legal, and regulatory affairs teams.
Regulatory watchpoints
- Tariff alignment. Confirm that Open Access Transmission Tariffs and business practice manuals embed AAR methodologies, data access provisions for transmission customers, and limited-use waivers consistent with FERC’s November 2023 rehearing order.
- Transparency obligations. Ensure public posting of seasonal and near-term ratings, methodology summaries, and forecast sources so state regulators and market participants can test just-and-reasonable rate compliance.
- Audit preparedness. Assemble evidentiary packages—calculation logs, override approvals, and stakeholder meeting minutes—in anticipation of FERC Office of Enforcement spot checks and NERC regional compliance audits.
Stakeholder engagement
- State coordination. Brief state public utility commissions on tariff revisions and congestion relief impacts, highlighting how AARs interact with resource adequacy and transmission expansion cases.
- RTO governance. Prepare briefing decks for market committees explaining implementation status, exception processes, and data portal availability ahead of July settlement cycles.
- Congressional oversight. Track inquiries from Senate and House energy committees, providing talking points on reliability benefits, wildfire mitigation, and consumer rate implications tied to Order 881.
Sources
Zeph Tech counsels policy leads on Order 881 filings, coordinating tariff narratives, transparency portals, and oversight briefings before the July 2025 enforcement sweep.