Overview
Steptoe partner Dan Mullen is quoted in a Law360 article titled “FERC a Big-League Enforcer 10 Years After EPAct of 2005.” The article, published August 11, discusses the Energy Policy Act (EPAct) of 2005 and the significant enforcement powers it granted the Federal Energy Regulatory Commission (FERC) to crack down on energy market manipulation.
Mr. Mullen, a former FERC investigations chief, says: "We're really still at the beginning of the EPAct enforcement regime. It's such a broad waterfront, and we're seeing little points of clarity along the way, but we don't have the full picture yet.”
The article states that FERC is no longer the sleepy agency simply presiding over electricity and gas rate-making cases; it is now also the overseer of a sprawling market enforcement regime capable of handing down fines of $1 million per day, per violation. “FERC has quickly established that it's not a do-nothing, toothless regime. You ignore FERC at your peril," Mr. Mullen says.
The full article can be read at Law360 (subscription required).
