Law & Lawyers

Cambridge Energy Research Associates Chairman Daniel Yergin captures in a few words oil's extraordinary past. Might those words one day describe the next 100 years of natural gas development? Talking with Yergin in early November, I found a man convinced that the forces that shaped a global oil market are at work in shaping a global market for natural gas. I'll be sharing some of his words with you.

On Oct. 22, FERC ruled that FERC-regulated entities must file their cash management agreements with the commission and notify the commission when their proprietary capital ratio drops below 30 percent, and when it subsequently returns to or exceeds 30 percent. FERC’s ruling comes in response to analysis that found “severe record keeping deficiencies” by some FERC-regulated entities. This problem has led credit rating agencies like Fitch Ratings to warn that consolidated cash management accounts and failure to document fund transfers among affiliated companies as intercompany loans could be factors contributing to a U.S. bankruptcy court’s decision to consolidate a solvent company in the bankruptcy proceeding of its affiliate.

ISO New England wants to become a regional transmission organization. But just the idea — prior to any official filing at FERC — has come under attack. ISO-NE is going to find rough waters ahead, despite a three-year effort aimed at a smooth transition to becoming an RTO. And now with the Oct. 31 filing of the 2,000-plus-page RTO proposal at FERC, the stage is set for these battles to be fought, again.

LMP enhances reliability in a manner that no penalty regime can achieve.