Compliance, Audits & Enforcement Practice
Issue Alerts
FERC Adopts New Information Posting Requirements for Interstate and Major Non-Interstate Gas Pipelines
Susan Olenchuk, Gregory JungeNovember 24, 2008
FERC issued a Final Rule adopting new regulations that require certain “major non-interstate pipelines” and interstate pipelines to publicly post certain operational and scheduling information. “Major non-interstate pipelines” will have 150 days from the date of publication in the Federal Register to comply with the Final Rule. Interstate pipelines must comply with the new regulations 60 days from the date of publication in the Federal Register.
FERC Reaffirms Modifications to Capacity Release Regulations
Susan Olenchuk, Megan CeronskyNovember 24, 2008
FERC issued an order reaffirming and clarifying its recently-adopted modifications to its regulations governing the release of firm transportation capacity on interstate natural gas pipelines. The revised regulations become effective 30 days after publication in the Federal Register.
FERC Seeks Comments on Whether to Require Intrastate and Hinshaw Pipelines that Provide Interstate Services to Post Details of Transportation Transactions
Susan Olenchuk, Justin MoellerNovember 24, 2008
FERC issued a Notice of Inquiry to explore whether intrastate pipelines and Hinshaw pipelines providing interstate transportation and storage services should be required to post details of their transactions with shippers in a manner comparable to the posting requirements of interstate pipelines. Comments are due 60 days after the NOI is published in the Federal Register.
FERC Issues Policy Statement on Key Elements of Compliance Programs
Doug Smith, Vincenzo Franco, Shay MillerOctober 21, 2008
FERC issued a Policy Statement on Compliance, which provides additional guidance on the key elements of internal compliance programs that FERC will consider in deciding whether to reduce or forego potential civil penalties for violations.
FERC Issues Revised Standards of Conduct for Transmission Providers
Susan Olenchuk, Mike ChaseOctober 21, 2008
FERC issued a final rule revising the Standards of Conduct for Transmission Providers, applicable to interstate natural gas pipelines regulated under the Natural Gas Act and public utilities regulated under the Federal Power Act. The revised Standards have three core elements: an independent functioning rule, a transparency rule, and a no-conduit rule. Transmission Providers may seek waivers. The new rules become effective 30 days after publication in the Federal Register, except that employees must be trained on the rule’s requirements within 60 days of the rule’s publication.
Seminars & Events
MEA Legal, Regulatory & Government Relations Roundtable
Mountain Thunder Lodge, Breckenridge, COSeptember 10, 2008
Van Ness Feldman's Tom Roberts will give an update on Washington, DC at 9:00 AM on September 12.
FERC Compliance Summit 2008
AED Conference Center, Washington, DCMay 19, 2008
Van Ness Feldman's Paul Korman will be a panelist at this conference during the discussion titled "What to do if you are faced with a compliance audit or investigation" on May 21st from 9:15-10:15 AM.
Conference on Enforcement Policy
Federal Energy Regulatory Commission, Washington, DCNovember 16, 2007
This Federal Energy Regulatory Commission conference examines the implementation of FERC's enforcement authority as expanded by the Energy Policy Act of 2005.