Alex Spratley

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On February 19, 2026, FERC dismissed a complaint filed by Baltimore Gas and Electric Company (BGE) against Transcontinental Gas Pipe Line Company, LLC (Transco) asserting that BGE had a contractual right to challenge its negotiated rate with Transco pursuant to section 5 of the Natural Gas Act (NGA). FERC held that BGE contractually waived its NGA section 5 rights with respect to its negotiated rate, and BGE therefore was required to pay the negotiated rate.

On January 29, 2025, FERC issued a certificate of public convenience and necessity (CPCN) to Transcontinental Gas Pipe Line Company, LLC (Transco) to construct and operate its Southeast Supply Enhancement Project (Project).

The Project expands Transco’s existing natural gas transmission system in Virginia and North Carolina and will add approximately…

On January 2, 2026, the D.C. Circuit declined to rehear en banc its prior order restoring the Clean Air Act’s (CAA) Title V affirmative defense to liability for excess emissions caused by emergency events. A group of environmental organizations had petitioned for rehearing en banc, arguing that the court’s reasoning violated D.C. Circuit precedent.

On December 18, 2025, FERC maintained that gas pipelines offering service under section 311 of the Natural Gas Policy Act (NGPA) that base their section 311 rates on state-approved rates must nonetheless comply with Straight-Fixed Variable (SFV) rate design or justify a departure from SFV.  Specifically, FERC denied Matterhorn Express…

On November 20, 2025, FERC terminated several long-pending rulemaking and policy dockets in an effort to provide “regulatory certainty.”  Specifically, FERC closed RM22-20, RM18-10, RM20-7, and PL20-7.

RM22-20 proposed requiring that any entity communicating with FERC or other specified organizations related to a matter subject to FERC’s jurisdiction submit accurate…

On November 25, 2025, FERC accepted the Midcontinent Independent System Operator, Inc.’s (MISO) proposal to expand the number of interconnection requests MISO may study under its temporary, fast-tracked generator interconnection process. FERC concluded that the proposal will help ensure interconnection customers are able to interconnect to the MISO transmission system in a reliable, efficient, and timely manner.

On October 28, 2025, the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) denied several petitions for review of FERC’s authorization of Gas Transmission NW, LLC’s (GTN) GTN Xpress compressor expansion project (Project).  Specifically, the Fifth Circuit (1) denied GTN’s petition for review challenging FERC’s denial of a…

On October 7, 2025, FERC rescinded the regulation that precluded natural gas pipeline companies from receiving authorization to proceed with construction of their new projects during the period for filing requests for rehearing of certificate orders, or while rehearing is pending. In doing so, FERC stated that its rescission will…

On September 30, 2025, the D.C. Circuit Court of Appeals denied a joint petition for review brought by Sierra Club and Appalachian Voices (together, Petitioners) challenging FERC’s grant of a certificate of public convenience and necessity (CPCN) to Tennessee Gas Pipeline Company (Tennessee Gas) to construct a new natural gas…

In the latest chapter in a long-running saga dealing with certain credits for transmission upgrades in the Southwest Power Pool (SPP), on September 18, 2025, FERC directed SPP to submit a compliance filing addressing certain aspects of SPP’s proposed plan (Refund Plan) for unwinding credit payment obligations assessed by SPP.