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Power & Pipes

FERC, CFTC, and State Energy Law Developments

On September 11, 2017, FERC granted a one-month extension for utilities and others affected by Hurricanes Harvey and Irma to submit certain filings. The extension applies to:

  • FERC-required form submissions,
  • nonstatutory filings such as compliance filings and deficiency letter responses, and
  • filings required by FERC jurisdictional tariffs.

For those filings, entities affected by the hurricanes need not file until after October 11, 2017.

Critically, the extension does not apply to those filings with deadlines imposed by statute. For entities whose filings are not covered by the extension, FERC's order notes that they may seek individual extensions of time where permitted under the applicable statute.

Please visit Morgan Lewis's Hurricane Recovery Resources center for this and other guidance on the complex legal and business implications of Hurricanes Harvey and Irma.