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Senate Energy Natural Resources Committee Examines Cyberattack Readiness of the US Bulk-Power System

On August 5, 2020, members of the Senate Energy and Natural Resources Committee questioned witnesses from the power industry and the federal government about the readiness of the United States bulk-power system (BPS) for a...more

Challenge to FERC Disclaimer of Jurisdiction over Net Metering Riles Small-Scale Solar Community

On April 14, 2020, the New England Ratepayers Association (NERA) filed a Petition for Declaratory Order (Petition) asking the Federal Energy Regulatory Commission (FERC or the Commission) to reverse its policy on net...more

Second Circuit Joins Seventh Circuit in Upholding Constitutionality of ZECs, Ending the Current Preemption Fight Against Nuclear...

On September 27, 2018, the U.S. Court of Appeals for the Second Circuit (Second Circuit) affirmed a district court’s finding that New York’s Zero Emissions Credit (ZEC) program is not preempted by federal law. The Second...more

Seventh Circuit Rejects Federal Preemption and Dormant Commerce Clause Challenges to Illinois Nuclear ZEC Program

In a surprisingly terse opinion, the U.S. Court of Appeals for the Seventh Circuit (Seventh Circuit) recently affirmed a district court’s finding that Illinois’ Zero Emissions Credit (ZEC) program is not preempted by federal...more

North Carolina Supreme Court Affirms Duke Energy’s Monopoly over Rooftop Solar

In September 2017, we reported on a Court of Appeals of North Carolina decision holding that entities installing solar panels on customer rooftops are “public utilities” under state law, at least if they retain ownership of...more

FERC Grapples with Accommodating State Policies in Wholesale Markets; Approves ISO New England Proposal for Subsidized Renewable...

Nearly a year after summoning stakeholders to discuss whether—and if so, how—the wholesale power markets should accommodate state policy goals, the Federal Energy Regulatory Commission (FERC or the “Commission”) has taken a...more

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

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

Proposed Bill Would Require State Public Utility Regulatory Authorities to Consider the Cost of Distributed Generation

On March 13, Sen. Jeff Flake (R-AZ) introduced the Ratepayer Fairness Act (RFA). The RFA would amend the Public Utility Regulatory Policies Act of 1978 (PURPA) to require that state public utility regulatory authorities and...more

FERC Takes Its Next Step on “Price Formation” in Organized Markets

On December 15, 2016, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) proposing to revise its regulations to require that each Regional Transmission Organization or Independent...more

12/23/2016  /  Comment Period , FERC , ISOs , NPRM , RTO , Utilities Sector

FERC Proposes Wide-Ranging New Regulations to Remedy Barriers to Wholesale Market Participation by Energy Storage and Distributed...

At its November 17, 2016 Open Meeting, the Federal Energy Regulatory Commission (“FERC” or “Commission”) proposed to amend its regulations to address and remove barriers to the participation of electric storage resources and...more

12/9/2016  /  Energy Storage , FERC , ISOs , NPRM , RTO , Utilities Sector

FERC Adopts New Regulations Allowing Higher-Priced Energy Offers in Organized Electricity Markets

At its November Open Meeting, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued a Final Rule (Order No. 831) directing the Regional Transmission Organizations and Independent System Operators...more

PJM Alternative to Expanding MOPR Leaves Questions Unanswered

On August 18, 2016, PJM Interconnection, L.L.C. (“PJM”) presented aproposal to its stakeholders outlining a possible mechanism for mitigating the potential impact on capacity prices in the PJM market of generation units...more

Recent Complaints Highlight Continued Friction between State Policy Goals and Federally Regulated Wholesale Power Markets

On June 24, 2016, two complaints were filed with the Federal Energy Regulatory Commission (“Commission or FERC”) that highlight the continued tension between state policy initiatives and the mandatory centralized capacity...more

D.C. Circuit Vacates FERC’s Controversial Demand Response Rule

On May 23, the United States Court of Appeals for the D.C. Circuit vacated in its entirety FERC’s controversial rule governing demand response resources in wholesale energy markets, known as “Order 745.”1 The majority...more

Utilities and Regulators Contemplate The Potential Costs Of Enhanced Physical Security

The security of the electric grid, both cyber- and physical, recently has received much public attention due to publicity surrounding a sniper attack on a California substation (see our blog post on grid security here). But...more

2/24/2014  /  Energy Sector , FERC , NERC , Utilities Sector

FERC Responds to Senate Inquiry about Physical Grid Security

On February 11, 2014, Acting Chairman Cheryl A. LaFleur of the Federal Energy Regulatory Commission (FERC) responded to a letter from four members of the Senate, which asked if further regulatory measures were needed to...more

2/17/2014  /  FERC , Infrastructure , Utilities Sector

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

Fourth Circuit Upholds FERC Transmission Incentives Order Despite Intervening Change in Policy

On January 24, the U.S. Court of Appeals for the Fourth Circuit upheld an order issued by the Federal Energy Regulatory Commission (FERC) in 2012 denying rehearing (Rehearing Order) of a 2008 order granting Virginia Electric...more

FERC Issues Notice of Alleged Violations In Connection with 2011 Blackout

On January 22, 2014, the staff (Staff) of the Office of Enforcement of the Federal Energy Regulatory Commission (FERC of the Commission) issued a Staff Notice of Alleged Violations (Preliminary Notice) relating to a September...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

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