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.
Jackie Triggs
Jackie focuses her practice on energy regulation, advising electric and gas utilities, independent power producers, renewable developers, and other market participants on matters before the Federal Energy Regulatory Commission (FERC) and state utility commissions. She helps clients secure regulatory approvals under the Federal Power Act, maintain compliance with FERC’s market-based rate and reporting requirements, and navigate RTO/ISO tariff rules and market-behavior standards. Jackie also represents clients in FERC and NERC investigations, audits, and self-reporting matters, as well as in settlement proceedings and administrative litigation.