FERC Issues Notice of Proposed Rulemaking Aimed At Increasing Incentives for Transmission Investment

After a 2-1 vote, on March 20, 2020, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued a Notice of Proposed Rulemaking (“NOPR”), proposing to revise its existing electric transmission incentives policy and corresponding regulations to enhance opportunities for utilities to qualify for and receive transmission incentives, including additional return on equity (“ROE”) adders in transmission rates, for transmission projects that ensure reliability of the grid or reduce the cost of delivered power by relieving transmission congestion. [1] The Commission proposes to...
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COVID-19: EPA Enforcement Discretion Policy

Today, the U.S. Environmental Protection Agency (EPA) issued a policy memorandum on the exercise of enforcement discretion due to the evolving impact of the COVID-19 pandemic in the United States. Susan Parker Bodine, Assistant Administrator for Enforcement and Compliance Assurance (OECA) posted the memorandum on EPA's website for all governmental and private-sector partners. Key message "The EPA will exercise the enforcement discretion specified below for noncompliance covered by this temporary policy and resulting from the COVID-19 pandemic, if regulated entities take the steps applicable...

COVID-19 and “Electronic” Execution of English Law Documents

In light of the on-going Covid-19 pandemic, many organisations are implementing remote working policies and limiting access to offices in order to effect social distancing measures. Notwithstanding the changes to usual working practices, organisations continue to enter into binding contractual arrangements with their commercial counterparties. From a practical perspective, remote working policies mean that authorised signatories may no longer have the ability to execute English law governed documents in the usual way, which would be by attending physical signing meetings, or following “...

Tips for Trading Compliance During a Pandemic

As many workplaces shutter and transition to telecommuting in response to the Novel Coronavirus (COVID-19), we are reminded that change always brings with it compliance risk. Even if your company has an emergency plan in place, assessing its effectiveness early and making adjustments as needed can avoid lapses in compliance. So what should compliance professionals at energy trading companies be thinking about right now? First, ensure compliance with existing policies . Most companies limit out-of-office trading and after-hours-trading and may prohibit it except under limited circumstances...

Unitization: Comments on 2020 AIPN Model International Unitization and Unit Operating Agreement

AIPN 2020 UUOA The Association of International Petroleum Negotiators ( AIPN ) has published the 2020 Model International Unitization and Unit Operating Agreement ( 2020 AIPN UUOA ) – an update to the AIPN’s 2006 model form Unitization and Unit Operating Agreement ( 2006 AIPN 2006 ). Bracewell looks at the key provisions in the AIPN 2020 UUOA, and the key differences between the 2020 AIPN UUOA and the 2006 AIPN UUOA. The AIPN’s Guidance Notes to the 2020 AIPN UUOA are a helpful resource when considering the 2020 AIPN UUOA. What is unitization? An oil or gas reservoir may straddle adjacent...

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