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Federal Energy Regulatory Commission Enforcement Actions Regulatory Requirements

Foley & Lardner LLP

FERC Issues Guidance on Treatment of Criminal Regulatory Offenses

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On June 16, 2025, the Federal Energy Regulatory Commission (FERC) issued a Notice of Guidance regarding the consistency of its existing policies for referring alleged criminal regulatory offenses to the Department of Justice...more

Troutman Pepper Locke

FERC Accepts SPP’s Tariff Revisions Incorporating a Mark-to-Auction Mechanism for SPP’s Transmission Congestion Rights Market

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On March 20, 2025, FERC approved Southwest Power Pool, Inc.’s (“SPP”) tariff revisions to incorporate a mark-to-auction collateral requirement for SPP’s Transmission Congestion Rights (“TCR”) market. In doing so, FERC found...more

Troutman Pepper Locke

FERC Grants BP Energy’s Complaint Appealing CAISO Meter Data Reporting Penalty

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On February 27, 2025, FERC granted a complaint filed by BP Energy Retail Company California LLC (“BP Energy” or “Company”) under sections 206 and 306 of the Federal Power Act appealing a penalty the California Independent...more

Baker Botts L.L.P.

FERC Approves First Enforcement Settlement Involving Power Plant Operations by Bitcoin Mining Company.

Baker Botts L.L.P. on

Bitcoin mining company pays $1.42 million for violating PJM’s tariff in relation to its power plant operations. On January 30, 2025, the Federal Energy Regulatory Commission (“FERC”) approved a settlement agreement...more

Vinson & Elkins LLP

FERC Settles Decade-Old Enforcement Allegations

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In 2016, a new play called Hamilton was dominating Broadway, Pokémon Go was all the rage, and the Summer Olympics were held in Rio. Also that year, the Federal Energy Regulatory Commission (“Commission” or “FERC”) issued an...more

Troutman Pepper Locke

PSE&G to Pay $6.6 Million Penalty for Failing to Provide Full and Accurate Information to PJM

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On December 5, 2024, the Federal Energy Regulatory Commission (“FERC”) approved Public Service Electric and Gas Company’s settlement agreement (“PSE&G”) to pay a $6.6 million civil penalty to resolve an ongoing investigation...more

Steptoe & Johnson PLLC

Supreme Court Limits the Use of Federal Administrative Law Judges; Related FERC Cases Pending

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On April 14, 2023, the U.S. Supreme Court issued an opinion that is expected to result in historic changes to the Federal Energy Regulatory Commission’s (FERC) use of in-house administrative law judges (ALJs). In Axon...more

Morgan Lewis

Fourth Circuit Sides with FERC on Statute of Limitations in Some FPA Enforcement Proceedings

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The US Court of Appeals for the Fourth Circuit  resolved a question of first impression on February 11 on when the statute of limitations period commences for civil enforcement claims brought by the Federal Energy Regulatory...more

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