Articles by Bruce Richardson

by: Bruce Richardson, David Tewksbury, Kelsey Desloover and Neil Levy

Two federal district courts hold that entities targeted by FERC enforcement actions who seek de novo review under the Federal Power Act are entitled to procedural due process rights of an ordinary civil action governed by the Federal Rules of Civil Procedure.Read more

by: Bruce Richardson, David Tewksbury, Neil Levy and Stephanie Lim

FERC issued a notice of proposed rulemaking addressing the collection of certain data from sellers making sales at market-based rates and entities trading virtual products or holding financial transmission rights. The NOPR also proposes changes to FERC’s requirements with respect to other information submitted for market-based rate purposes. Read more

by: Bruce Richardson, David Tewksbury, Neil Levy and Stephanie Lim

FERC has recently issued a Notice of Inquiry seeking comments on possible reforms to its rules and regulations relating to primary frequency response.Read more

by: Bruce Richardson, David Tewksbury and Neil Levy

FERC recently issued a Rehearing Order reaffirming its prior findings in Chehalis Power Generating, L.P. that addresses the distinction between an initial rate and a changed rate. The Rehearing Order has potential implications with respect to FERC-jurisdictional service provided for no compensation.Read more

by: Bruce Richardson, Jeffrey H. Perry and Neil Levy

On March 7, 2014, the Federal Energy Regulatory Commission (FERC) directed the North American Electric Reliability Corporation (NERC) to develop reliability standards requiring owners and operators of the Bulk-Power System to address risks due to physical security threats and vulnerabilities in order to enhance the resilience of the transmission grid.Read more

by: Bruce Richardson, David Tewksbury, Neil Levy and Stephanie Lim

FERC recently issued a notice of proposed rulemaking stating that it intends to approve Version 5 of the Critical Infrastructure Protection Reliability Standards submitted by the North American Electric Reliability Corporation, which pertain to the cyber security of the bulk electric system.Read more

by: Alexander Haas, Bruce Richardson, Eleanor Hill, Phyllis Sumner and Pulina Whitaker

President Obama’s Executive Order on Cybersecurity and the EU’s Cybersecurity Strategy and Proposed Directive indicate greater regulatory burdens and disclosure requirements on the energy sector and electric grid operators.Read more

by: Bruce Richardson, David Tewksbury, Grace Su and Neil Levy

FERC’s NOPR was prompted by concerns that the interaction of the Earth’s magnetic field and solar events can cause low frequency geomagnetically induced currents to flow along the surface of the Earth and into the bulk-power system.Read more

by: Bruce Richardson, David Tewksbury and Grace Su

Amended regulations ensuring efficient and cost-effective investment decisions are necessary because changes in generation mix are driving the demand for additional investment in transmission.Read more