News & Analysis as of

Qualifying Facility Public Utility

Davis Wright Tremaine LLP

D.C. Circuit Upholds FERC’s “Send-Out” Approach to PURPA

In a win for independent power producers, the U.S. Court of Appeals for the District of Columbia Circuit ("D.C. Circuit" or the "Court") recently affirmed the Federal Energy Regulatory Commission's ("FERC's") "send-out"...more

Troutman Pepper Locke

D.C. Circuit Upholds FERC Interpretation of PURPA Size Limitation Based on “Send out” to Point of Interconnection

Troutman Pepper Locke on

On February 14, 2023, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) upheld FERC’s March 2021 order granting Broadview Solar, LLC’s (“Broadview”) hybrid solar and battery project...more

Stoel Rives - Renewable + Law

Updated FERC Guidance on Qualifying Facility Certifications

FERC issued two notable orders this spring in Irradiant Partners, LP (Docket No. EL22-8-000) and Dalreed Solar (Docket No. QF20-1037-002) that provide further guidance on qualifying facility (QF) certifications.  Here are the...more

Morgan Lewis - Power & Pipes

FERC Allows Cooperatives to Share QF Purchase Obligation

FERC granted a partial waiver requested by a generation and transmission service cooperative (Petitioner) of certain obligations under FERC’s regulations implementing Section 210 of the Public Utility Regulatory Act of 1978...more

Akin Gump Strauss Hauer & Feld LLP

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

Bracewell LLP

FERC Proposes New Treatment of Fuel Cells Under PURPA

Bracewell LLP on

Comments for FERC’s Notice of Proposed Rulemaking on Fuel Cell Energy Output (“NOPR”) are due tomorrow, November 25, 2020. In the NOPR, FERC proposes to modify its regulations for qualifying facility (“QF”) status under the...more

Akin Gump Strauss Hauer & Feld LLP

Divided FERC Revamps PURPA Regulations: What the Final Rule Does and Why It Matters

On July 16, 2020, the Federal Energy Regulatory Commission (FERC or the Commission) overhauled its regulations under the Public Utility Regulatory Policies Act of 1978 (PURPA), which had been largely unchanged since 1980....more

Orrick, Herrington & Sutcliffe LLP

FERC Revisions to PURPA Rules Create Uncertainty For “Qualifying” Renewable and Cogeneration Projects

On July 16, 2020, the Federal Energy Regulatory Commission (“FERC”) issued a final rule that largely adopts FERC’s proposed revisions to its regulations under the Public Utility Regulatory Policies Act of 1978 (“PURPA”)....more

Bracewell LLP

FERC Finalizes Reforms to PURPA Regulations

Bracewell LLP on

On July 16, 2020, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued Order No. 872, a final rule that the Commission explains is intended to implement its statutory mandate to update rules promulgated...more

Beveridge & Diamond PC

FERC Proposes the First Comprehensive Reform of its PURPA Regulations Since 1980: Renewables Under the Gun?

Beveridge & Diamond PC on

On September 19, 2019, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) proposing to comprehensively rewrite its rules for implementing the Public Utility Regulatory Policies Act...more

Alston & Bird

FERC Proposes Rule Revisions Under the Public Utility Regulatory Policies Act of 1978

Alston & Bird on

The Federal Energy Regulatory Commission seeks to revise its PURPA regulations after nearly 40 years of growth in the energy industry, but not everyone is on board. Our Energy Group highlights the notable proposed changes and...more

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights - September 2019 #3

FERC Proposes to Modernize PURPA Regulations - "The Federal Energy Regulatory Commission proposed to modernize its regulations governing small power producers and cogenerators under the Public Utility Regulatory Policies...more

Ballard Spahr LLP

FERC Proposes Extensive Revisions to PURPA Regulations

Ballard Spahr LLP on

The Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) seeking comments on proposed revisions to regulations that implement the Public Utility Regulatory Policies Act of 1978 (PURPA)....more

Saul Ewing LLP

FERC Proposes Major Modifications to PURPA - Some Regions May Be More Affected Than Others

Saul Ewing LLP on

The Federal Energy Regulatory Commission (“FERC”) issued a proposed rulemaking on September 19, 2019, that entails a sweeping overhaul of the Public Utility Policy Act of 1978 ("PURPA") which could have significant impact on...more

Nelson Mullins Riley & Scarborough LLP

FERC Proposes Most Significant Reforms to Regulations Implementing PURPA in Almost Forty Years with Significant Implications for...

Last week, the Federal Energy Regulatory Commission (“FERC”) issued a Notice of Proposed Rulemaking (“NOPR”) to modernize its regulations governing small power producers and cogenerators under the Public Utility Regulatory...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Public Utility Regulatory Policies Act Regulations: Federal Energy Regulatory Commission Proposed Revisions

The Federal Energy Regulatory Commission (“FERC”) proposed on September 19th what it describes as a modernization of its regulations governing small power producers and co-generators under the Public Utility Regulatory...more

Davis Wright Tremaine LLP

FERC Proposes Modernizing PURPA Regulations; Chairman Outlines Other Priorities

Modernization of regulations implementing the Public Utility Regulatory Policies Act of 1978 (PURPA) has long been a high priority for FERC Chairman Neil Chatterjee. ...more

Husch Blackwell LLP

FERC Proposes Sweeping Changes To PURPA Regulations

Husch Blackwell LLP on

The Federal Energy Regulatory Commission (FERC) issued a sweeping Notice of Proposed Rulemaking (NOPR) proposing to dramatically reform its regulations that implement the Public Utility Regulatory Policies Act of 1978...more

King & Spalding

The Ninth Circuit Affirms that California QF Contracts Do Not Comply with PURPA

King & Spalding on

On July 29, 2019, the United States Court of Appeals for the Ninth Circuit issued its decision in Winding Creek Solar LLC v. Peterman et al, Case Nos. 17-17531, 17-17532 (9th Cir. July 29, 2019), which affirmed the judgment...more

Sheppard Mullin Richter & Hampton LLP

9th Circuit Says CPUC’s Standard Contract and Re-MAT Program for Certain Renewable Generators are not PURPA Compliant

In a recent opinion, the Ninth Circuit held that the California Public Utilities Commission’s (CPUC) Renewable Market Adjusting Tariff (Re-MAT) program and alternative Qualifying Facility (QF) standard offer contract...more

Holland & Knight LLP

The Light Shines for CA QFs: The Ninth Circuit Finds PURPA Preempts CA Renewable Energy Program

Holland & Knight LLP on

On July 30, 2019, a Ninth Circuit Court of Appeal panel unanimously held that the federal Public Utility Regulatory Policy Act (PURPA) preempts two components of California's Renewable Market Adjusting Tariff (Re-MAT)...more

Holland & Knight LLP

Court Holds Federal Law Preempts California Regulations Promoting Renewable Energy Projects

Holland & Knight LLP on

• A solar developer claimed that California Public Utilities Commission (CPUC) orders promoting solar and wind generation under 3 megawatts (MW) prevented it from securing a contract from a utility under the Public Utility...more

Akin Gump Strauss Hauer & Feld LLP

Federal Court Finds California PURPA Programs Non-Compliant

In a decision issued last week, the U.S. District Court for the Northern District of California granted summary judgment in favor of Winding Creek Solar LLC (“Winding Creek”). Winding Creek had alleged that certain California...more

Akin Gump Strauss Hauer & Feld LLP

First Circuit Decision Finds No Private Right of Action Under PURPA Against a Utility

On November 13, 2017, the U.S. Court of Appeals for the 1st Circuit held in Allco Renewable Energy Ltd. v. Mass. Elec. Co. that a Qualifying Facility (QF) does not have a private right of action against a utility company...more

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