FERC has relied on Form 2 data to initiate proceedings under Section 5 of the Natural Gas Act (NGA) to change prospectively the transmission rates of natural gas companies. In the coming years, FERC may start taking a similar approach to electric transmission rates, relying on Form 1 data to initiate proceedings under Section 206 of the Federal Power Act (FPA) to change electric transmission rates.
Morgan Lewis Energy partners Mark R. Haskell and Stephen M. Spina and associate Bryan L. Clark presented a one-hour webinar that compared and contrasted FERC's authority under Section 5 of the NGA to its authority under Section 206 of the FPA and discussed the structure and framework of a FERC-initiated rate complaint.