How to prepare for mandatory enforcement.
Stephen M. Spina and Michael C. Griffen are partners in the Energy Practice Group, and William F. Hederman Jr. is the executive director of the Energy Resources Group, for the law firm of Morgan Lewis & Bockius LLP in Washington, D.C. Spina can be reached at sspina@morganlewis.com, Griffen can be reached at mgriffen@morganlewis.com, and Hederman can be reached at whederman@morganlewis.com.
FERC staff’s Preliminary Assessment of NERC’s proposed reliability standards identified a number of potential deficiencies, many of which NERC plans to address. What adjustments must be made by users, owners, and operators of the bulk power system in the new era of mandatory compliance?
The Energy Policy Act of 2005 (EPACT) brought sweeping reform to the regulation of energy markets and the enforcement of market rules, as well as to regulation of the transmission systems that are the backbone of those markets. Over the last few months, the breadth and scope of that reform has come into even sharper focus. New rules, promulgated by the Federal Energy Regulatory Commission (FERC) in a host of areas, significantly have altered the regulatory risk landscape.