FERC Decisions May Disrupt Intrastate Sales
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NARUC, EWURA & ICC First Partnership Activity
In April 1992, the Federal Energy Regulatory Commission (FERC) issued its Order 636 and transformed the interstate natural gas transportation segment of the industry forever. Under it, interstate natural gas pipeline companies were required to restructure their operations by November 1993 and split-off any non-regulated merchant
Federal Preemption and State Water Law
Supreme Court decisions spanning four decades (First Iowa Hydro-Electric Cooperative v. Federal Power Commission and California v. FERC); resulting in the preservation of only proprietary interests created by state laws, and not all state la ws; it is still not an instan ce where there is no room for the States. They may not
VIA ELECTRONIC SUBMISSION
exclusive jurisdiction over wholesale sales in ERCOT and directly contradict long-established precedent. FERC s authority and its comprehensive regulatory structure would be similarly compromised and subject tocollateral attack through litigation, to the detriment of electricity customers and the competitive market as a whole.