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FERC Orders 1920 and 1977: The Latest Evolution in Transmission Planning and Oversight

The US federal government’s evolving role in overseeing transmission development took another leap forward after the Federal Energy Regulatory Commission (FERC) issued Orders 1920 and 1977, two new rules that mark FERC’s...more

FERC Increases Maximum Civil Monetary Penalty

The Federal Energy Regulatory Commission (FERC) issued a final rule on January 12 amending its regulations governing the maximum civil monetary penalties assessable for violations of statutes, rules, and orders within FERC’s...more

New Legislation Would Give FERC Explicit Authority to Impose Trader Bans

US Senators Maria Cantwell (D-WA) and Catherine Cortez Masto (D-NV) introduced legislation on July 28, 2022, to provide FERC with the authority to temporarily or permanently ban any person from trading or transacting in...more

District Court Ruling Would Impute Liability to Employer in Nearly All FERC Enforcement Matters

A recent district court order highlights the importance of maintaining a strong compliance program with effective compliance controls and practices, while highlighting the risk of employee misconduct for the enterprise...more

Ohio District Court Rejects FERC Enforcement of Disgorgement and Joint and Several Liability

The US District Court for the Southern District of Ohio held on November 29, 2021, that in actions commenced under 16 USC Section 823b, district courts have the power to decide whether FERC can enforce civil penalties but do...more

DC Circuit Rejects FERC’s Use of Tolling Orders; FERC Issues Statement Asking Congress to Act

A decision by the US Court of Appeals for the DC Circuit on June 30 rejected the near routine use by the Federal Energy Regulatory Commission of tolling orders to prevent rehearing requests from being denied by operation of...more

Fourth Circuit Sides with FERC on Statute of Limitations in Some FPA Enforcement Proceedings

The US Court of Appeals for the Fourth Circuit  resolved a question of first impression on February 11 on when the statute of limitations period commences for civil enforcement claims brought by the Federal Energy Regulatory...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

DC Circuit Ruling Threatens to Topple FERC Tax Allowance Policy

Court rules that FERC policy permitting a tax allowance for pass-through entities may unjustifiably permit “double-recovery” of tax expense. On July 1, the US Court of Appeals for the District of Columbia Circuit issued...more

CFTC Proposes to Allow Private Lawsuits for Transactions in RTOs and ISOs

The proposal could create uncertainty for market participants and raise jurisdictional questions about which regulator should police power markets....more

FERC Signals Intention to Closely Scrutinize Late Interventions

Movants must clear high hurdle once parties reach settlement in principle. On March 9, the Federal Energy Regulatory Commission (FERC or the Commission) issued an order in Maritimes & Northeast Pipeline, LLC (Maritimes...more

US Supreme Court Holds FERC Has Jurisdiction Over Demand Response

Decision brings more clarity to jurisdictional boundaries between state public utility regulatory commissions and FERC set forth by the Federal Power Act. On January 25, the US Supreme Court, in a 6-2 decision, ruled in...more

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