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FERC Proposes Landmark Penalty for Alleged Energy Efficiency Resource Capacity Market Manipulation

On December 16, 2024, the Federal Energy Regulatory Commission (FERC or the Commission) issued an Order to Show Cause and Notice of Proposed Penalty proposing to assess staggering civil penalties against American Efficient,...more

FERC Seeks to Eliminate Utility Self-Funding of Network Upgrades

On June 13, 2024, the Federal Energy Regulatory Commission (FERC or the Commission) issued an Order (the Show Cause Order) requiring PJM Interconnection, L.L.C. (PJM), Midcontinent Independent System Operator Inc. (MISO),...more

FERC Doubles Down on Scrutiny of Investor Ties with Public Utilities

On July 3, 2023, the Federal Energy Regulatory Commission (FERC or the Commission) issued an order confirming a more aggressive posture towards scrutinizing the ability of investors to exercise control over public utilities...more

FERC Again Proposes Incentives for Voluntary Cybersecurity Investments

On September 22, 2022, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued a Notice of Proposed Rulemaking (NOPR) proposing revisions to its regulations to establish rate incentives for public utilities...more

FERC Reverts to Its Traditional Analysis for Determining “Power Production Capacity” of Small Power Production QFs

On March 19, 2021, a divided Federal Energy Regulatory Commission (FERC or the “Commission”) reverted to its long-standing “send out” analysis for determining the “power production capacity” of a small power production...more

FERC Further Extends Effective Date and Compliance Deadlines for Market-Based Rate Relational Database Filings

Of interest to entities who hold, or might seek, authorization from the Federal Energy Regulatory Commission (FERC or the “Commission”) to engage in sales for resale of electric energy, capacity or ancillary services at...more

FERC Proposes to Clarify and Streamline Its Interlocking Directorate Regulations

On July 19, 2018, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued a Notice of Proposed Rulemaking (NOPR) to update and clarify its regulations covering “interlocking directorate” positions (i.e.,...more

FERC Holds Certain Passive Equity Interests in Public Utilities Are “Non-Voting Securities” for Purposes of Section 203 of the...

On October 4, 2017, in a decision with significant implications for the energy project finance community, the Federal Energy Regulatory Commission (FERC or the “Commission”) granted a petition for declaratory order filed by...more

Sens. Inhofe and Heinrich Propose to Amend Section 203 of the Federal Power Act to “Provide Parity to FERC Reviews” of Certain...

On September 27, 2017, Sens. James M. Inhofe (R-OK) and Martin T. Heinrich (D-NM) introduced S. 1860, the Parity Across Reviews Act (“PARs Act”), which, if enacted, would add a $10 million value threshold to the requirement...more

FERC and American Transmission Company Settle on $205,000 Penalty for Violations of Sections 203 and 205 of the Federal Power Act

On August 28, 2017, the Federal Energy Regulatory Commission (FERC or the “Commission”) approved a Stipulation and Consent Agreement between FERC’s Office of Enforcement (OE) and American Transmission Company, LLC (ATC) to...more

Facing a Potentially Lengthy Non quorum Period, FERC Delegates Further Authority to Its Staff

On February 3, 2017, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued an order (the “Delegation Order”) delegating “further authority” to its staff—beyond the existing delegations of authority...more

Renewable Energy Investor Group Asks FERC to Designate Certain Passive Equity Interests in Public Utilities as “Non-Voting...

On December 9, 2016, a group of investors in renewable energy projects (“Petitioners”) asked the Federal Energy Regulatory Commission (FERC) to find that certain non-managing (i.e., passive) “tax equity” interests in public...more

FERC Seeks Comment On Potential Modifications To Its Market Power Analyses

On September 22, 2016, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) seeking comment on whether and, if so, how FERC might modify or enhance its methods for identifying and assessing market...more

Supreme Court Invalidates Maryland Power Plant Subsidy Program and Reaffirms FERC’s Exclusive Authority Over Wholesale Capacity...

On April 19, 2016, for the second time in three months, the Supreme Court of the United States reaffirmed the exclusive jurisdiction of the Federal Energy Regulatory Commission (FERC) over the formation of wholesale rates in...more

FERC Reaffirms and Clarifies Exemption for Certain Qualifying Facilities from Section 203 of the Federal Power Act

On November 19, 2015, the Federal Energy Regulatory Commission (FERC) reaffirmed and clarified the exemption for certain Qualifying Facilities (QFs) from Section 203 of the Federal Power Act (FPA) set forth in Section...more

FERC Approves Settlement for Pipeline Failure to Publicly Post Auction Notices

On July 30, 2015, two weeks after the Office of Enforcement (OE) of the Federal Energy Regulatory Commission (FERC) issued a staff notice of alleged violations (“Notice”) to Columbia Gas Transmission LLC (“Columbia Gas”) for...more

FERC Issues Order to Show Cause and Notice of Proposed Penalty for Alleged Market Manipulation in New England

On February 2, 2015, the Federal Energy Regulatory Commission (FERC) issued an Order to Show Cause and Notice of Proposed Penalty (Show Cause Order) directing Calgary-based Maxim Power Corporation and certain of its...more

FERC Issues Order to Show Cause and Notice of Proposed Penalties to Powhatan Energy Fund, LLC and Related Parties

On December 17, 2014, as amended December 18, 2014, the Federal Energy Regulatory Commission (FERC) issued an Order to Show Cause and Notice of Proposed Penalty (Show Cause Order)1 directing Houlian (Alan) Chen, HEEP Fund,...more

Third Circuit Affirms District Court Decision Invalidating New Jersey’s Long-Term Capacity Pilot Program

On September 11, 2014, a three-judge panel of the U.S. Court of Appeals for the Third Circuit unanimously affirmed an October 2013 decision of the U.S. District Court for the District of New Jersey that New Jersey’s Long-Term...more

DOE Issues Draft Triennial National Electric Transmission Congestion Study

On August 19, 2014, the U.S. Department of Energy (DOE) issued a Notice of Public Comment on its draft triennial National Electric Transmission Congestion Study (“Congestion Study”). DOE prepares such congestion studies every...more

FERC Announces New Approach for Determining the Return on Equity for Electric Utilities

On June 19, 2014, the Federal Energy Regulatory Commission (FERC) issued Opinion No. 531, an order affirming in part and reversing in part an administrative law judge’s August 2013 Initial Decision concerning a complaint...more

ITC Companies Settle FERC Enforcement Action Regarding Federal Power Act Section 203 and 205 Violations for $750,000

On March 11, 2014, the Federal Energy Regulatory Commission (FERC) issued an order approving a settlement between the FERC Office of Enforcement (OE) and four subsidiaries of ITC Holdings Corp. (the ITC Companies) that...more

FERC Alleges Numerous Federal Power Act Section 203 and 205 Violations by Subsidiaries of ITC Holdings Corp.

On February 11, 2014, the staff of the Office of Enforcement (OE) of the Federal Energy Regulatory Commission (FERC) issued a Staff Notice of Alleged Violations (Notice) stating that it has preliminarily determined that four...more

FERC Orders Civil Penalties and Disgorgement for Manipulation of ISO New England Load Response Program

On August 29, 2013, the Federal Energy Regulatory Commission (FERC) issued three orders assessing civil penalties on, and requiring disgorgement of profits by, Lincoln Paper and Tissue, LLC (Lincoln), Competitive Energy...more

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