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Filing Requirements Federal Energy Regulatory Commission

Troutman Pepper Locke

Order No. 1920-B Affirms FERC’s Long-Term Transmission Planning and Cost Allocation Rule

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On April 11, 2025, FERC issued Order No. 1920-B, which clarified and maintained key requirements from Order No. 1920-A regarding long-term transmission planning and cost allocation. FERC clarified that transmission providers...more

Foley Hoag LLP - Energy & Climate Counsel

Energy Storage Sands Continue to Shift at Last NYISO Task Force Meeting Before Order No. 2023 Compliance Filing

On Friday, March 15, 2024, the NYISO hosted what is expected to be the last of its Interconnection Issues Task Force (“IITF”) meetings before making its FERC Order No. 2023 compliance filing on April 3, and it was clear that...more

Troutman Pepper Locke

FERC Proposes Changes to Filing Requirements and Data Collection for Electric Quarterly Report

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On October 19, 2023, FERC issued a Notice of Proposed Rule Making (“NOPR”) proposing various changes to its Electric Quarterly Report (“EQR”) filing requirements. According to FERC, the proposed changes are designed to update...more

Foley Hoag LLP - Energy & Climate Counsel

NYISO Order No. 2023 Compliance Update: Summary of November 3 Partial Compliance Filing and Summary of November 2 Interconnection...

This post is the second in our ongoing series following the NYISO’s compliance with FERC Order No. 2023. In today’s post, we cover the NYISO’s November 3, 2023 partial compliance filing made with FERC, as well as provide an...more

Akin Gump Strauss Hauer & Feld LLP

FERC Proposes to Streamline EQR Data Collection and Filing Process

On October 19, 2023, the Federal Energy Regulatory Commission (FERC or the Commission) proposed changes to the method of collection and data being collected in its Electric Quarterly Reports (EQRs).1 Specifically, FERC...more

McGuireWoods LLP

FERC Proposes Overhauling Electronic Quarterly Report Filing Process and Data Submission

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On Oct. 19, 2023, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) in Docket No. RM23-9-000 to modify filing processes for Electronic Quarterly Reports (EQRs) and revise and...more

Schwabe, Williamson & Wyatt PC

EPA’s Proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule Could Cause Ripple Effects With Project...

On June 1, 2022, the U.S. Environmental Protection Agency (EPA) issued a proposed rule that would modify its requirements for water quality certification under Clean Water Act (CWA) Section 401 (the “Proposed Rule”). The...more

Troutman Pepper Locke

FERC Provides Additional Time to Prepare WECC Cost Justification Filings

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On March 24, 2022, FERC issued an order granting a motion to extend the deadline for submitting the cost justification filings required for spot market sales in the Western Electricity Coordinating Council (“WECC”) region...more

Morgan Lewis - Power & Pipes

FERC Reiterates Importance of Filing Updated Form 556 for Qualifying Facilities

In an order denying a request to waive filing requirements triggered by changes in ownership of qualifying facility (QF) projects, the Federal Energy Regulatory Commission reiterated the importance of ensuring QF filings,...more

Morgan Lewis - Power & Pipes

FERC Further Delays Implementation of MBR Database Reporting Requirements

FERC recently issued a notice of extension of time further extending, by three months, the compliance dates for FERC’s new market-based rate (MBR) relationship database filing requirements under Order No. 860. This extension...more

Troutman Pepper Locke

FERC Revises Filing Requirements for Certain Small Hydroelectric Facilities

Troutman Pepper Locke on

On July 15, 2021, the Federal Energy Regulatory Commission (“Commission” or “FERC”) issued a Final Rule amending its regulations pertaining to: (1) the information required to be filed with a notice of intent to construct a...more

Troutman Pepper Locke

FERC Clarifies Policy for Ensuring Timely Filing in the Event of E-Filing Malfunction

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On August 18, 2020, the Federal Energy Regulatory Commission (FERC) issued an order clarifying its filing requirements in the event its e-filing system malfunctions....more

Akin Gump Strauss Hauer & Feld LLP

FERC Clarifies New Requirements for Certain Filings

On August 18, 2020, the Federal Energy Regulatory Commission (FERC or the “Commission”) clarified its Order No. 862, issued in August 2019, in which FERC changed its regulations to require that any nonelectronic filing to be...more

Akin Gump Strauss Hauer & Feld LLP

FERC Announces New Requirements for Certain Filings and Submissions

On August 27, 2019, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued a final rule revising its regulations to require all hard copy and hand delivered filings and submissions—except those sent via...more

Sheppard Mullin Richter & Hampton LLP

FERC Order No. 860 Mandates New Market-Based Rate Filing and Reporting Requirements for Sellers of Electric Energy

On July 18, 2019, the Federal Energy Regulatory Commission issued Order No. 860. The order requires entities with or seeking market-based rate authority (sellers) to submit certain data related to FERC’s market power...more

Akin Gump Strauss Hauer & Feld LLP

FERC Eases Small Residential Solar QF Filing Burden for Sunrun

On April 18, 2019, the Federal Energy Regulatory Commission (FERC) granted Sunrun, Inc. (Sunrun) limited waivers of FERC’s filing requirements for obtaining qualifying small power production facility (QF) status under the...more

Holland & Knight LLP

FERC Sets $10 Million Threshold on Public Utility Merger Approvals

Holland & Knight LLP on

On Feb. 21, 2019, the Federal Energy Regulation Commission (FERC) issued a final rule revising its regulations governing public utility mergers or consolidations. The primary effect of this rule is to set a $10 million...more

Akin Gump Strauss Hauer & Feld LLP

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

Akin Gump Strauss Hauer & Feld LLP

FERC Denies Waiver for Failure to File PURPA Qualifying Facility Self-Certification

On May 17, 2018, the Federal Energy Regulatory Commission (FERC or the “Commission”) granted in part and denied in part a request by Zeeland Farm Services, Inc. (“Zeeland”) for a waiver of FERC’s regulations requiring small...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Regulatory Reform Agenda for FERC

Deregulation was a major theme during the first year of the Trump administration, with President Donald Trump calling on agencies to strike two regulations for each one they added. Many have taken up this call for regulatory...more

Cozen O'Connor

Failure to Report Uplift Payments, Capacity Sales, Corrective Action Taken, Highlight FERC EQR Audit

Cozen O'Connor on

The Federal Energy Regulatory Commission’s (FERC) recent audit of a company participating in numerous wholesale power markets highlights errors that can occur with electronic quarterly reports as well as the actions suggested...more

Morgan Lewis

FERC Upholds and Clarifies Reforms to Market-Based Rate Program

Morgan Lewis on

The clarifications address concerns from market participants but leave some questions unanswered. On May 19, the Federal Energy Regulatory Commission (FERC or the Commission) issued Order No. 816-A, which upholds and...more

Davis Wright Tremaine LLP

FERC Modifies Filing Requirements for Market-Based Rate Sellers and Clarifies Gen-Tie Priority Rights Rules

At its October 2015 meeting, the Federal Energy Regulatory Commission ("FERC" or “Commission”) issued three orders pertaining to its market-based rate regulations. In Order No. 816, the Commission adopted proposals to update...more

Morrison & Foerster LLP

FERC Substantially Modifies Filing Requirements for Market-Based Rate Sellers and Clarifies Rules on Priority Rights Granted to...

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On October 16, 2015, the Federal Energy Regulatory Commission (FERC or “Commission”) issued Order No. 816 that revises filing requirements for market-based rate (MBR) sellers of electric energy, capacity, and ancillary...more

Akin Gump Strauss Hauer & Feld LLP

FERC Eliminates Annual Retail Purchaser List Filing Requirement

On July 16, 2015, the Federal Energy Regulatory Commission (FERC) eliminated the requirement for certain public utilities, including regional transmission organizations (RTOs), independent system operators (ISOs) and exempt...more

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