FERC Order No 845 Reforms Generator Interconnection Process Advances Energy Storage

by Orrick, Herrington & Sutcliffe LLP
Contact

Orrick, Herrington & Sutcliffe LLP

On April 19, 2018 the Federal Energy Regulatory Commission (FERC) adopted reforms to the procedures (LGIP) and pro forma agreement (LGIA) pursuant to which generators can interconnect with electric utility transmission grids. FERC's goal is to improve certainty for developers of electric generating and storage projects that interconnect to the interstate transmission grid, promote informed decisions about generator interconnection costs and timing, and enhance the interconnection process.

Since FERC issued its landmark Order No. 2003, generators have been able to rely on FERC's standard form of interconnection agreement and related procedures to interconnect, rather than having to negotiate interconnection arrangements individually.

However, despite the availability of standard procedures and agreements, generator interconnections continue to present substantial uncertainties with respect to timing and costs of constructing interconnection facilities. Advancements in technology, including the deployment of utility-scale energy storage devices, such as lithium ion batteries, have presented additional challenges, as developers seek to interconnect combined generation and storage projects that use the same interconnection capacity for generated and stored energy sales. 

1. Advancing Energy Storage, Right-Sizing Interconnection Facilities and Upgrades

Several of the reforms adopted in Order No. 845 will benefit developers of energy storage resources. These reforms represent a natural extension of FERC's efforts over the past several years to remove barriers for energy storage resources to participate in wholesale energy, capacity and ancillary services markets. Although certain of the reforms outlined below will benefit developers of renewable and conventional generation, these reforms could have a more profound impact on development and interconnection of energy storage projects, both stand-alone storage and combined storage plus generation projects.

Definition of Generating Facility

In addition to developing stand-alone energy storage devices, developers are increasingly adding storage to existing renewable generation projects or developing new combined generation and storage projects. Previously, to interconnect their storage facilities to the transmission grid, storage developers were required to use rules and agreements designed for the interconnection of generating facilities – i.e. renewable or thermal facilities that generate, but do not store, energy. Although some transmission providers have interpreted the term "generating facility" to include storage, FERC determined that a revised definition was necessary to provide clarity across all wholesale electric markets. Accordingly, Order No. 845 directed transmission providers to revise the definition of "generating facility" in the LGIP and pro forma LGIA to include storage devices, whether developed as a stand-alone project or in combination with another generating facility. The revision mirrors FERC's 2013 directive to revise the small generator interconnection procedures and agreement to include storage within the definition of generating facility.

Interconnection Service Below Full Generation Facility Capacity

Another problematic issue for both energy storage and generation developers has been the requirement under the current LGIP for developers to request interconnection service based on the full generating or storage capacity of their planned facilities. Order No. 845 explained that, for example, advances in wind turbine technologies that slightly increase capacity and that occur after an interconnection request has been filed could require the submission of a material modification request; instead, the developer might prefer to maintain the original capacity rating. Also, to avoid substantial network upgrades, a developer may conclude that it is economic to limit the facility's output, if that will avoid the need to pay for the upgrades.

To accommodate these types of concerns and avoid the construction and cost of unnecessary interconnection facilities and transmission upgrades, FERC directed transmission providers to revise their LGIPs to allow interconnection customers to request interconnection service that is lower than the full generating capacity of their planned generation or storage facilities. In turn, interconnection customers will be required to install control and protection devices to prevent the generating facility from injecting energy above the specified level of interconnection capacity. The change in the LGIP should help generation and storage developers avoid paying for unnecessary interconnection facilities and transmission upgrades, and thereby reduce interconnection costs and construction timelines.

Use of Surplus Interconnection Capacity

Interconnection customers, and especially those with intermittent or peaking generation assets, do not use all of their allocated and paid for interconnection capacity during many periods. As a result, this "surplus" interconnection capacity can be used by another generator or energy storage device when it is not being used by the interconnection customer. Following the lead of the MISO "net zero" option adopted in 2012, Order No. 845 directed transmission providers to revise their LGIPs and standard LGIAs to establish an expedited process for the interconnection of additional generating facilities to use any surplus interconnection rights. As stated above, transmission providers currently conduct interconnection studies to identify interconnection facilities and network upgrades based on the nameplate capacity of a planned generating capacity. The LGIP and LGIA revisions directed by FERC will allow new generating facilities, including storage, to take advantage of surplus interconnection capacity through an expedited interconnection process. Accordingly, entities requesting surplus interconnection service will not be required to obtain interconnection rights for their additional generator or storage capacity via the standard interconnection queue process.

FERC rejected comments that surplus capacity should be offered to third parties on an open access basis. Instead, FERC ruled the interconnection customer or its affiliate has priority to use surplus interconnection capacity. If neither the customer nor its affiliate wishes to use surplus capacity, it can be offered to unaffiliated third parties. FERC expressly determined that assignment of surplus capacity is not subject to open access principles, and thus modified the approach previously adopted for MISO net zero interconnection service.

A potential risk relating to using surplus interconnection service is that it is tied to the original interconnection agreement. If the interconnection agreement for the original customer terminates, so does the agreement for the surplus customer. Still, the availability of surplus interconnection service will create opportunities for developers to interconnect projects relatively quickly and likely at a much lower cost than if they went through the standard interconnection process.

2. Improved Certainty for Interconnection Customers

In Order No. 845, FERC determined that "the current interconnection process may hinder timely development of new generation, stifle competition, result in uncertainty and inaccurate information, or potentially unduly discriminate against new technologies." In addition, FERC expressed concern that these deficiencies in the interconnection process could become exacerbated if left unresolved. Accordingly, FERC directed transmission providers to make additional reforms to their LGIP and LGIA that are intended to benefit interconnection customers by increasing certainty in the interconnection process.

Option to Build

To interconnect generation projects to the grid, developers and transmission providers must coordinate the construction and ownership of (1) discrete transmission facilities – known as generation tie-lines, (2) a substation at the point where the generation tie-line interconnects with the grid, and (3) upgrades to the transmission providers transmission system. Under FERC's standard LGIA, the interconnection customer is responsible for the costs to construct all of these facilities, subject to refund for qualifying transmission upgrades; but the transmission provider is responsible for constructing and owning some interconnection facilities and all transmission upgrades. If the transmission provider cannot construct its facilities in time to meet the interconnection customer's construction timeline, the interconnection customer can elect to build the facilities itself.

To give interconnection customers more control and certainty in the construction of interconnection facilities and transmission upgrades, FERC directed transmission providers to revise their standard LGIA to allow interconnection customers the option to build regardless of whether or not the transmission provider can meet the interconnection customer's construction schedule. In building the transmission provider's interconnection facilities and network upgrades, the interconnection customer must comply with all laws that would be applicable to the transmission provider, including reliability standards. FERC acknowledged, however, that there may be barriers outside of FERC's jurisdiction that prevent interconnection customers from exercising this option to build (e.g. state laws and eminent domain). Interconnection customers will not be able to exercise the option to build if they are unable to construct for reasons outside of FERC's jurisdiction.

Dispute Resolution

Parties to a standard LGIA have the option to pursue binding arbitration to resolve a dispute, but only if all of the parties to the LGIA consent to the arbitration. In response to concerns from developers about arbitration and the unilateral ability of a single party to block it, FERC required transmission providers to revise the standard LGIA to allow any disputing party to unilaterally exercise a right to pursue non-binding dispute resolution. Under the revised procedures, the disputing parties must appoint a neutral decision-maker within 30 days of the receipt of a request for non-binding dispute resolution. In turn, the decision-maker must render a decision within 60 days of his or her appointment. At the close of the dispute resolution process, the interconnection customer could still pursue arbitration or submit a complaint to FERC under Section 206 of the Federal Power Act. However, like an arbitration, a FERC complaint proceeding could require several months to conclude. Accordingly, the new dispute resolution procedures are intended to provide a more efficient alternative to resolve disputes between LGIA parties.

3. Promoting Informed Interconnection Decisions

Among the most serious interconnection risks for generation developers are delays in the interconnection study process and determinations by the transmission owner or provider that a project's interconnection is contingent upon the construction of upgrades to be constructed by another developer. The uncertainty around these risks has resulted in disputes between transmission owners and developers, and in some developers withdrawing their projects from consideration before obtaining a generator interconnection agreement. Commenters stated that if developers had more information about these risks, they would be better equipped to make decisions about whether or not to proceed with their projects or to initiate a dispute with the interconnection transmission owner.

Published Method for Identifying Contingent Facilities

A perennial challenge for many interconnection customers has been the lack of transparency around a transmission provider's identification of interconnection facilities and network upgrades that must be developed and funded by higher-queued interconnection customers as a condition of granting service to the lower-queued customer. Accordingly, FERC directed transmission providers to include, both in their interconnection study reports and in their pro forma interconnection agreements, the transmission provider's method for identifying contingent facilities. In addition, transmission providers must post sufficient base case data, including all assumptions and contingency lists, to their open access same-time information system (OASIS) site or a password-protected website. Once implemented, interconnection customers will be able to verify the need for the contingent facilities identified in their interconnection studies and agreements.

Interconnection Study Deadlines

Transmission providers must conduct interconnection studies to identify facilities necessary to interconnect a generation or storage project to the grid. Under the current LGIP, transmission providers must use "reasonable efforts" to complete interconnection studies on a timely basis. Without information about a transmission provider's success in timely completing other studies, it has been difficult for developers to determine whether the transmission provider has satisfied the "reasonable efforts" standard. Accordingly, FERC revised the LGIP to require transmission providers to post interconnection study metrics online (to their OASIS websites) and to file information reports with FERC. The new requirements will increase transparency of interconnection study timelines, thereby enabling interconnection customers to determine if the transmission provider is satisfying the "reasonable efforts" standard.

4. Interconnection Process Enhancements

Order No. 845 directed transmission providers to implement further changes to their interconnection procedures that are intended to remove barriers to entry for generation developers. As discussed above, Order No. 845 directed transmission providers to revise their interconnection procedures to allow interconnection customers to request interconnection service that is below the full capacity of their planned generating facilities. In addition, Order No. 845 addressed the use of surplus interconnection capacity. As discussed below, Order No. 845 also directed transmission providers to offer provisional interconnection agreements and to develop procedures for identifying permissible technology changes proposed by interconnection customers.

Provisional Interconnection Agreements

As discussed above, delays in the interconnection study process can pose a significant risk to the timely construction of a planned generation project. Currently offered on a voluntary basis by some transmission providers, provisional interconnection agreements offer developers the ability to interconnect a project before all studies or necessary transmission upgrades are complete, subject to operating restrictions. For some developers, a provisional interconnection agreement can help avoid a default under a power purchase agreement that sets a deadline for initial deliveries of power. Accordingly, Order No. 845 required transmission providers to offer provisional interconnection service to their interconnection customers. Transmission providers will continue to have discretion on managing provisional interconnection studies and agreements. FERC stated that it is not adopting a pro forma provisional interconnection agreement at this time.

Technology Changes

It is not uncommon for a developer to decide, after submitting an interconnection request, to change the technology that it intends to use to construct its generating facility, including generating turbines, transformers and other equipment. Even small technological advancements can reap significant returns in improved costs or power production. However, under the current interconnection process, it can be difficult for a developer to determine whether a change in equipment will represent a material modification of its interconnection request, and thereby require the developer to abandon its existing interconnection position and submit a new request. Accordingly, FERC directed transmission providers to revise their interconnection procedures to include a process for technological changes. In addition, transmission providers must define permissible technological advancements that would not constitute a material modification.

Order No. 845 will take effect on July 23, 2018. Subject to FERC's action on requests for rehearing or appeals, transmission providers must prepare and submit revisions to their LGIP and pro forma LGIAs by no later than August 7, 2018. The full text of Order No. 845 is available through the FERC website (click here).

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Orrick, Herrington & Sutcliffe LLP | Attorney Advertising

Written by:

Orrick, Herrington & Sutcliffe LLP
Contact
more
less

Orrick, Herrington & Sutcliffe LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.