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CARES Act: Key Takeaways for Energy Companies

President Donald Trump signed the $2.2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act) into law on March 27. The CARES Act aims to offer economic relief to companies and their employees due...more

PHMSA Notice to Operators: Stay of Enforcement and Enforcement Discretion for Certain Requirements Due to COVID-19

In response to the US president’s declaration of a national emergency due to the coronavirus (COVID-19) pandemic, on March 20 the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a notice to operators...more

PHMSA Issues Final Rule on Underground Natural Gas Storage Facilities Safety

The Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) long-awaited final rule on the minimum safety standards for underground natural gas storage facilities (UNGSFs) was published in the February 12 Federal...more

CFTC Awards $15 Million in Five Whistleblower Awards in 2019; Cumulative Awards Total $100 Million

The Commodity Futures Trading Commission (CFTC) recently released its Annual Report on the Whistleblower Program and Customer Education Initiatives for fiscal year (FY) 2019. The report, which details the operation of the...more

CFTC Settles With Energy Company for Acting as an Unregistered Futures Commission Merchant

The Commodity Futures Trading Commission (CFTC) filed and settled charges on October 24 against Upstream Energy Services LLC (Upstream Energy) for acting as an unregistered futures commission merchant. The Commission’s order...more

10/28/2019  /  CFTC , Energy Sector , FERC , Natural Gas , Oil & Gas

Executive Orders May Limit Effect of Agency Guidance Documents

President Donald Trump signed a pair of executive orders on October 9 that may limit the impact of an agency’s use of informal guidance documents. The executive orders express concern that agency guidance, which includes...more

FERC Must Explain Departure from Methodology for Evaluating Index Rate Increases

On June 14, the US Court of Appeals for the DC Circuit vacated and remanded two challenged orders and directed FERC to explain or reconsider whether data made available after a challenged rate increase becomes effective...more

6/26/2019  /  Energy Sector , FERC , Oil & Gas

First Circuit to Consider FERC Filed Rate Doctrine Implications on Retail Energy Prices

Currently at issue before the US Court of Appeals for the First Circuit is whether the filed rate doctrine prevents a court from assessing the reasonableness of a utility’s rates in the retail market. Under the filed rate...more

FERC Rescinds Its Policy of Issuing Notices of Alleged Violations

FERC issued an order on May 16 rescinding its 2009 policy of issuing Notices of Alleged Violations (NAVs) after the subject of an investigation is given an opportunity to respond to FERC Enforcement Staff’s preliminary...more

Federal Courts Continue to Define State Permitting Authority Affecting Interstate Pipeline Projects

The US Supreme Court has denied a petition for certiorari filed by the Delaware Riverkeeper Network, which challenged a decision by the US Court of Appeals for the Third Circuit concerning Pennsylvania’s water quality...more

OMB Expands FERC Actions Subject to Prepublication Review

A recent policy statement from the Office of Management and Budget (OMB) instructs departments and agencies—including independent agencies like FERC—to submit “guidance documents, general statements of policy, and...more

PJM Interconnection Implements New Requirements for Generator Interest and Asset Sales

Regional transmission operator PJM Interconnection, L.L.C. recently changed its operating manual to require that generating entities experiencing direct or indirect changes in ownership or control notify PJM of such changes...more

7/11/2018  /  Energy Sector , FERC , PJM

FERC Adopts Reforms to Address Inefficiencies in Interconnection Process

The revisions by the Federal Energy Regulatory Commission relate to the Large Generator Interconnection Procedures and Large Generator Interconnection Agreement, and are intended to provide increased certainty and additional...more

PHMSA Sets Safety Standards for Underground Gas Storage Facilities

Operators of underground storage facilities will need to assess the operational safety of their facilities and document the implementation of safety solutions....more

FERC Proposes to Integrate Electric Storage into Organized Markets

The proposed rule recognizes the physical and operational characteristics of electric storage resources and distributed energy resource aggregators and removes barriers to their participation in organized wholesale electric...more

PHMSA Implements Authority to Issue Emergency Orders

Interim Final Rule allows the Pipeline and Hazardous Materials Safety Administration (PHMSA) to respond immediately to unsafe conditions or practices that pose an imminent hazard to public health and safety or to the...more

CFTC Proposes Amendments to Whistleblower Awards Process and Anti-Retaliation Authority

The amendments would make the CFTC’s whistleblower awards process more uniform with the SEC’s program and would enable the CFTC to bring enforcement actions against employers that retaliate against whistleblowers....more

Federal Court Grants Full Civil Trial to FERC Enforcement Target

The decision will likely affect the strategies of enforcement targets in electric market manipulation cases. For the first time, a federal district judge has held that a review of a Federal Energy Regulatory Commission’s...more

FERC Terminates Proceeding That Would Increase Reporting of Natural Gas Sales

On November 17, 2015, the Federal Energy Regulatory Commission (FERC) issued an order terminating its inquiry on potentially requiring jurisdictional sellers to submit quarterly reports on natural gas transactions....more

Battery Energy Storage Facilities May Be Subject to Wholesale Distribution Charges

FERC found that a storage device using a utility’s distribution system in charging mode should share in the costs of the distribution system. On June 18, the Federal Energy Regulatory Commission (FERC) upheld an earlier...more

6/25/2015  /  Batteries , Electricity , Energy Storage , FERC

FERC Amends Pro Forma SGIP and SGIA

Reforms are expected to reduce the time and cost required to process small generator requests for Interconnection Customers while maintaining reliability, increasing energy supply, and removing barriers to the development of...more

12/3/2013  /  Eligibility , Fast Track Process , FERC , SGIA , SGIP

NERC Fines Generator for Violations Related to Lead Line Operations

Filing reminds generators with significant high-voltage tie lines that they can be subject to Reliability Standards typically applied to transmission owners and transmission operators. ...more

FERC Lacks Authority Over Commodity Futures Contracts

The D.C. Circuit clarifies that FERC may prohibit manipulative trading only in markets outside of the CFTC's exclusive jurisdiction over commodity futures contracts. On March 15, the U.S. Court of Appeals for the...more

FERC Reframes Nexus Test for Transmission Incentives Applications

Rate incentives may become more difficult to obtain; applicants are provided guidance on showings they are expected to make. On November 15, the Federal Energy Regulatory Commission (FERC) issued a Policy Statement...more

11/19/2012
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