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Power & Pipes

FERC, CFTC, and State Energy Law Developments

On November 17, 2015, the Federal Energy Regulatory Commission (FERC) issued an order terminating its inquiry on potentially requiring jurisdictional sellers to submit quarterly reports on natural gas transactions.[1]

Three years ago, FERC issued a Notice of Inquiry and requested comments on its proposal to require quarterly reporting of every natural gas transaction within its jurisdiction under the Natural Gas Act (NGA) that entails physical delivery for the next day (or, next day gas) or for the next month (or, next month gas).[2] Section 23 of the NGA directs FERC “to facilitate price transparency in markets for the sale or transportation of physical natural gas in interstate commerce” and grants FERC the authority to require market participants to submit information on the availability and prices of natural gas sold at wholesale and in interstate commerce.

[1] Enhanced Natural Gas Market Transparency, 153 FERC ¶ 61,174 (2015).

[2] Enhanced Natural Gas Market Transparency, 141 FERC ¶ 61,124 (2012).