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FERC Issues New CIP Compliance Recommendations

FERC Staff issued an October 4 report on Commission-led critical infrastructure protection (CIP) reliability audits completed during fiscal year 2019. The report provides lessons learned and identifies voluntary practices...more

FERC GC to Be Nominated as New Commissioner

President Donald Trump announced on Monday his intention to nominate FERC General Counsel James Danly to fill the remaining Republican position at FERC. That position has been vacant since the untimely passing of former...more

FERC Proposes to Revise Qualifying Facility Rates and Requirements

FERC issued a notice of proposed rulemaking (NOPR) on September 19 announcing its intent to revise key rules governing the status and rights of Qualifying Facilities (QFs). These revisions include proposed changes to the...more

FERC Staff Proposes Risky Plan to Identify Utilities with Cybersecurity Violations

Facing what it deems an “unprecedented number of FOIA requests” for nonpublic information related to utility violations of the North American Electric Reliability Corporation (NERC) critical infrastructure protection (CIP)...more

FERC Finds That Hydro Investments Could Support Longer New License Terms

For the first time, FERC has found that significant investments in an existing licensed hydroelectric facility by a licensee will be considered when establishing the license term in a relicensing proceeding, potentially...more

CEQ Issues Draft NEPA Guidance on Consideration of GHGs

The Council on Environmental Quality (CEQ) published draft guidance on June 26 to address how agencies implementing environmental reviews under the National Environmental Policy Act (NEPA) should consider greenhouse gas (GHG)...more

FERC Imposes Extensive Relational Database Requirements on MBR Holders

The Federal Energy Regulatory Commission (FERC or Commission) on July 18 issued a rule, initially proposed in July 2016, restructuring the way it collects certain data for market-based rate (MBR) purposes and significantly...more

FERC Simplifies MBR Screen Requirements in Multiple Markets

Wholesale electricity sellers that are not government owned are subject to regulation by the Federal Energy Regulatory Commission. Obtaining FERC approval to sell wholesale electricity at “market-based rates” (which is nearly...more

FERC Requires a Business to Pay Off a Related Business’s Debts Before Entering RTO Market

When a business entity that is regulated by the Federal Energy Regulatory Commission (FERC) is closely related to another business entity, FERC takes the position that under some circumstances it may treat the two different...more

FERC Approves Expanded Cyber Incident Reporting Requirements for Electric Utilities

FERC recently approved proposed Reliability Standard CIP-008-6, which expands the mandatory reporting requirements for Cyber Security Incidents that attempt to compromise the operation of the bulk power system. Under the new...more

FERC Report Highlights Changing Resource Mix

A recent grid reliability report issued by staff members of the Offices of Electric Reliability and Enforcement within FERC evaluating the upcoming operating season underscored the changing generation resource mix in the...more

FERC Staff Provides Lessons Learned for Electric Utility Cybersecurity

FERC Staff issued a report on March 29 on Commission-led critical infrastructure protection (CIP) reliability audits completed for fiscal years 2016 through 2018. The report provides lessons learned from those audits, as well...more

FERC Proposes to Reduce Market-Based Rate Statistical Study Requirements in Some Organized Markets

The Federal Energy Regulatory Commission issued a Notice of Proposed Rulemaking on December 20 that would partially relax the competitive market power study requirements that apply to public utilities with Market-Based Rate...more

FERC Clarifies that Cogen Waiver, Steam Restoration Do Not Result in ‘New’ QF Status

A Qualifying Cogeneration Facility (Cogen QF) that improves or restores its thermal offtake need not fear the loss of its legal status or impairment of its power sales contracts solely because of its compliance efforts and...more

8/28/2018  /  Energy Sector , FERC , PURPA

PJM Interconnection Implements New Requirements for Generator Interest and Asset Sales

Regional transmission operator PJM Interconnection, L.L.C. recently changed its operating manual to require that generating entities experiencing direct or indirect changes in ownership or control notify PJM of such changes...more

7/11/2018  /  Energy Sector , FERC , PJM

NERC Issues Recommendations on Inverter-related Solar Outages

Inverter disconnect events increasingly pose a reliability risk with the growth of solar generation. On June 8, the North American Electric Reliability Corporation (NERC) released its report on the loss of 1,200 MW of solar...more

6/12/2017  /  Energy Sector , FERC , NERC , Solar Energy

2016 FERC Enforcement Report: Trends Continue, with More Court Fights

The report shows a continued focus on manipulative conduct in energy markets as well as serious mandatory reliability standards violations, but also shows FERC’s increasing caseload in federal court....more

Federal Court Grants Full Civil Trial to FERC Enforcement Target

The decision will likely affect the strategies of enforcement targets in electric market manipulation cases. For the first time, a federal district judge has held that a review of a Federal Energy Regulatory Commission’s...more

FERC to Strengthen Protections for Infrastructure Information

Implementing new statutory authority, FERC proposes revised regulations to secure and share Critical Electric Infrastructure Information and penalize its unauthorized disclosure....more

FERC Finalizes Hold-Harmless Policy and Strikes the Most Problematic Proposals

FERC guidance clarifies the scope of the hold-harmless commitments offered in electric utility mergers and acquisitions, but discards its initial proposal to make those commitments open-ended. On May 19, the Federal...more

Proposed FERC Regulations Would Grant FERC Access to NERC Non-Public Transmission and Generation System Databases

FERC proposes to grant itself access to NERC’s Transmission Availability Data System, Generating Availability Data System, and Protection System Misoperations Database. On September 17, the Federal Energy Regulatory...more

D.C. Circuit Rejects Challenges to FERC’s Order No. 1000

The court turned back all challenges to FERC’s order, which imposed major regional transmission planning requirements, concluding that FERC has adequately justified the order and acted within its statutory authority....more

FERC Approves Version 5 CIP Reliability Standards, Rejects Key Reforms

The Commission rejects NERC’s proposal to reform the existing “zero tolerance” to CIP compliance, describing the proposal as too ambiguous and unworkable. On November 22, the Federal Energy Regulatory Commission (FERC...more

NERC Fines Generator for Violations Related to Lead Line Operations

Filing reminds generators with significant high-voltage tie lines that they can be subject to Reliability Standards typically applied to transmission owners and transmission operators. ...more

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