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FERC Takes Action to Encourage Cybersecurity Investments

Building off its White Paper issued last summer, the Federal Energy Regulatory Commission (FERC or the “Commission”) has proposed changes to its regulations that would encourage more robust investment in cybersecurity...more

FERC Affirms Energy Storage Rule, Denies State Opt-Out

In an Order on Rehearing and Clarification issued at its May open meeting, the Federal Energy Regulatory Commission (FERC or “Commission”) generally affirmed Order No. 841, its 2018 Final Rule on electric storage. Electric...more

FERC Rejects Electric Generators’ Request to Adopt Centralized Capacity Market in California

In June 2018, CXA La Paloma, LLC (“La Paloma”) filed a complaint at the Federal Energy Regulatory Commission (FERC or “the Commission”) seeking to require the California Independent System Operator (CAISO) to implement a...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

Carbon Pricing Update: Assessing NYISO’s Carbon Pricing Straw Proposal

The New York Independent System Operator (NYISO) recently released a Carbon Pricing Straw Proposal (Proposal) to advance the State’s energy and environmental goals by reflecting the cost of carbon emissions in wholesale...more

Lack of Quorum Costs East Kentucky Power Cooperative in PURPA Dispute

The Federal Energy Regulatory Commission (FERC or the “Commission”) recently restored its quorum with the swearing in of Commissioners Neil Chatterjee and Robert Powelson, but the casualties from the six-month, quorumless...more

Federal Courts’ Dismissal of Pre-emption Challenges to Illinois and New York ZEC Nuclear Subsidies Returns Focus to FERC

On July 14, 2017, and July 25, 2017, the U.S. District Court for the Northern District of Illinois and the U.S. District Court for the Southern District of New York, respectively, dismissed challenges to the Illinois and New...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 Dismisses Electric Cooperatives’ Maryland Community Solar Program PURPA Case as Premature

On November 15, 2016, the Federal Energy Regulatory Commission (FERC) issued an order dismissing a petition for declaratory filed by two Maryland electric cooperatives requesting a FERC finding that regulations governing...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 Proposes $2.4 Million Civil Penalty for CAISO Power Trading Activities

On December 16, 2015, the Federal Energy Regulatory Commission (FERC or the Commission) issued an Order to Show Cause and Notice of Proposed Penalty (OSC) directing ETRACOM LLC and its principal member and trader, Michael...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

BP Case May Again Test Limits of FERC’s “In Connection With” Enforcement Jurisdiction

A Federal Energy Regulatory Commission (FERC) Administrative Law Judge last week issued an Initial Decision finding that BP America (BP) and certain related BP entities violated FERC’s Anti-Manipulation Rule. Following a...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 Proposed Policy Statement on “Hold Harmless” Commitments in Federal Power Act Section 203 Proceedings

The Federal Energy Regulatory Commission (FERC) last week issued a proposed policy statement to clarify FERC’s allowance of “hold harmless” commitments in applications filed under Section 203 of the Federal Power Act (FPA)....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

New York Association of Public Power Files Complaint to Reduce Niagara Mohawk Power Corporation’s ROE

On February 6, 2014, the New York Association of Public Power (NYAPP) filed a second complaint (Second Complaint) against Niagara Mohawk Power Corporation d/b/a National Grid (NMPC) asking the Federal Energy Regulatory...more

FERC Requests that U.S. District Court Affirm Penalties for Market Manipulation

On October 1, 2013, we reported here that the Federal Energy Regulatory Commission (FERC) issued orders on August 29, 2013, assessing civil penalties against, and requiring disgorgement of profits by, Lincoln Paper and...more

Federal Court Finds New Jersey’s Long-Term Capacity Pilot Project Unconstitutional

On October 11, 2013, the United States District Court for the District of New Jersey issued its decision in PPL Energyplus, LLC v. Hanna. This case follows a recent decision in which the U.S. District Court for the District...more

Federal Court Finds Maryland’s Long-Term Contract for Differences Unconstitutional

On September 30, 2013, the United States District Court for the District of Maryland issued its decision in PPL Energyplus, LLC v. Nazarian. The case has been watched by many for its potential implications with respect to...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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