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FERC Changes Policy Statements on Pipeline Certification and GHG Emissions to Draft Policy Statements, Seeks Comment on Draft...

On March 24, 2022, FERC changed course and designated the two policy statements it issued last month regarding the certification of interstate natural gas pipelines (“Updated Policy Statement”) and consideration of greenhouse...more

FERC Overhauls Existing Pipeline Project Analysis, Creates Separate Interim GHG Policy for Gas Infrastructure Projects.

On February 18, 2022, FERC issued two new, significant policies governing how FERC will review proposals for new natural gas pipeline projects (see February 18, 2022, Troutman Pepper Insight). Headlining these policies is...more

FERC Overhauls Existing Pipeline Project Analysis, Creates Separate Interim GHG Policy for Gas Infrastructure Projects

On February 17, the Federal Energy Regulatory Commission (FERC or Commission) announced two new, significant policies that may have a profound impact on both natural gas pipeline projects before the Commission and the...more

D.C. Circuit Grants Emergency Petition for Stay of FERC’s Order Terminating Killingly Energy Center’s ISO-NE Capacity Commitments

On February 4, 2022, the United States Court of Appeals for the District of Columbia Circuit (“DC Circuit”) issued a per curiam order granting NTE Connecticut, LLC’s (“NTE”) petition for issuance of a writ under the All Writs...more

FERC Announces New Policy on Interventions in Extension of Time Proceedings for Gas Pipeline Certificates

On January 20, 2022, FERC granted Adelphia Gateway, LLC’s (“Adelphia”) request for an 18-month extension of time, until June 20, 2023, to construct and place into service the proposed Adelphia Gateway Project. The order also...more

FERC Affirms QF Self-Certification for a Hybrid Solar and Battery Project, Prompting Dissent from Commissioner Danly

On December 17, 2021, FERC affirmed a Public Utility Regulatory Policies Act of 1978 (“PURPA”) qualifying facility (“QF”) self-certification for the Shields Valley Solar Facility (“Shields Valley”), a hybrid solar and battery...more

FERC Approves $300,000 Settlement Between ReliabilityFirst and Ohio Valley Electric Corp. for Violations of NERC Reliability...

On November 26, 2021, FERC issued a notice stating that it would not review a Notice of Penalty filed by the North American Electric Reliability Corporation (“NERC”) against Ohio Valley Electric Corporation (“OVEC”). FERC’s...more

12/14/2021  /  Electricity , Energy Sector , FERC , NERC

FERC and NERC Issued Final Report on the 2021 Winter Freeze

On November 16, 2021, staff from FERC, the North American Electric Reliability Corporation (“NERC”), and certain Regional Reliability Entities issued a final report on the 2021 winter storms that severely impacted the bulk...more

FERC Rejects Attempts to Waive $75 Million in Pipeline Penalties During Storm Uri

On October 21, 2021, FERC denied multiple complaints against Panhandle Eastern Pipe Line Company, LP (“Panhandle”) regarding its refusal to waive all penalties associated with Operational Flow Orders (“OFO”) issued during the...more

FERC Accepts Replacement Offer Cap for PJM Capacity Markets; PJM Requests Capacity Auction Delay to Implement New Offer Cap

On September 2, 2021, FERC accepted a new Market Seller Offer Cap (“MSOC”) in the PJM Interconnection, L.L.C. (“PJM”) capacity market that will require all capacity market sellers offering above $0/MW-day to, at their...more

9/30/2021  /  Energy Market , Energy Sector , FERC

D.C. Circuit Denies Petitions for Review; Holds that the Filed Rate Doctrine Prevents SPP from Reimbursing Customers for...

On August 27, 2021, in Oklahoma Gas and Electric Company v. FERC, Case No. 20-1062, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) denied petitions for review of FERC’s orders...more

9/16/2021  /  Energy Sector , FERC , OATT , Tariffs

Supreme Court Rules that PennEast, Gas Pipelines May Condemn State-Owned Land

On June 29, 2021, the Supreme Court of the United States ruled that a certificate of public convenience and necessity issued by FERC under section 7 of the Natural Gas Act (“NGA”) authorizes a private company to exercise...more

FERC Issues Order No. 2222-B, Setting Demand Response Opt-Out for Further Consideration

On June 17, 2021, FERC set aside its previous decision in Order No. 2222-A that allowed state regulatory authorities to prohibit demand response resources from participating in distributed energy resource (“DER”) aggregations...more

FERC Issues Show Cause Order Directing GreenHat Energy to Respond to Market Manipulation Claims

On May 20, 2021, FERC issued a Show Cause Order directing GreenHat Energy, LLC (“GreenHat”) and its owners to show why they did not violate the Federal Power Act, FERC’s regulations, the PJM Interconnection, L.L.C. (“PJM”)...more

FERC Revises Policy on Authorizing Pipelines to Commence Construction Pending Requests for Rehearing of Certificate Orders

On May 4, 2021, FERC issued Order No. 871-B, clarifying that the rule established in Order No. 871, which precludes FERC from authorizing natural gas pipeline companies to proceed with construction of approved pipeline...more

Mountain Valley Pipeline Construction to Resume over Opposition from Chairman Glick and Commissioner Clements

On March 24, 2021, FERC modified a December 17, 2020 order (“December Order”) while reaching the same overall result, allowing construction to recommence for a portion of the Mountain Valley Pipeline, LLC (“Mountain Valley”)...more

Richard Glick Named FERC Chairman

On January 21, 2021, President Biden named Richard Glick as the new FERC Chairman. Chairman Glick joined FERC as a Commissioner in 2017. He previously served as general counsel to the Democrats on the Senate Energy and...more

Mark C. Christie Sworn in as FERC Commissioner

On January 4, 2021, Mark C. Christie was sworn in as FERC’s newest Commissioner. The Senate previously confirmed the nomination of Commissioner Christie, along with the nomination of now-current-Commissioner Allison Clements,...more

Senate Confirms Christie and Clements to Fill Remaining Commission Seats

On November 30, 2020, in a late night voice vote, the U.S. Senate confirmed the nominations of Mark Christie and Allison Clements as FERC Commissioners. Once they are sworn in as Commissioners, the bipartisan pairing will...more

FERC Upholds Changes to PJM Reserve Market Design and E&AS Offset Calculation

On November 3, 2020, FERC upheld its May 2020 order finding PJM Interconnection, L.L.C.’s (“PJM”) reserve market design to be unjust and unreasonable, and establishing a replacement market design including, among other...more

11/16/2020  /  Energy Market , Energy Sector , FERC

FERC to Host Technical Conferences on Electric Vehicles and Credit Risk Management in Organized Wholesale Markets

On October 30, 2020, FERC announced that the FERC Chairman will convene a roundtable discussion on December 3, 2020 regarding the increased deployment of electric vehicles (“EVs”) and EV charging infrastructure nationwide and...more

FERC Finds Abrogation of Gas TSAs Would Not Be in the Public Interest Ahead of Possible Bankruptcy Proceeding

On October 28, 2020, FERC declined to abrogate or modify firm natural gas transportation service agreements (“Gulfport TSAs”) between Gulfport Energy Corporation (“Gulfport”) and Rockies Express Pipeline LLC (“Rockies...more

Commissioner Danly Objects to FERC’s Continued Practice of Granting Retroactive Waivers

On October 16, 2020, FERC issued a number of orders at its open meeting that addressed unrelated requests for retroactive waiver of various Regional Transmission Organization and utility tariff provisions. Commissioner James...more

FERC Accepts CAISO Rules Enhancing Demand Response Program for Electric Vehicle Charging Stations and Behind-the-Meter Energy...

On September 30, 2020, FERC accepted the California Independent System Operator Corporation’s (“CAISO”) proposals to: 1) permit electric vehicle charging stations to participate in CAISO’s demand response program separately...more

FERC Staff Clarifies Changes to Rehearing Practices Following Allegheny Decision

On September 17, 2020, at FERC’s Virtual Open Meeting, FERC Staff presented an overview of changes to its rehearing practices following the United States Court of Appeals for the District of Columbia Circuit’s (“D.C....more

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