Energy Oversight, Investigations & Enforcement
Troutman Sanders Energy Oversight, Investigations & Enforcement practice team represents and advises utilities, gas companies, power marketers, and market participants on a multitude of issues related to FERC’s statutes, rules, regulations and orders.
Our attorneys are fully versed in FERC’s Standards of Conduct, Affiliate Restrictions, interlocking positions regulations, tariff requirements and financial requirements. Our attorneys assist clients with creating and implementing compliance programs, and work collaboratively with clients to determine and spot issues and, if need be, assist in the preparation of self-reports.
Our Energy Oversight, Investigations & Enforcement practice team has vast experience in assisting clients with FERC audits, from pre-audits to audit preparation to on-site defense to representation during any civil penalty phase. Our attorneys work hand-in-hand with in-house attorneys, business people and engineers to jointly represent the best interests of our client and promote a just outcome.
Recent highlights include:
- Provided counsel and assistance to several utilities with audits and investigations by FERC’s Office of Enforcement regarding compliance with FERC’s Standards of Conduct, Affiliate Restrictions, and OASIS regulations and compliance with the utilities’ open access transmission tariffs.
- Created and provided compliance training for utilities regarding FERC’s rules and regulations including Standards of Conduct, Affiliate Restrictions and OATT compliance.
- Assisted in audit preparation and response to a FERC Financial Audit.
- Represented and counseled companies and individuals in FERC Office of Enforcement investigations into electricity trading activities.
- Represented clients in self-report and other FERC Office of Enforcement investigation matters.