Todd serves as chair of the Energy Enforcement practice group. He represents energy clients with enforcement and compliance matters involving the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the North American Electric Reliability Corporation (NERC) and other regulators, as well as related government and private litigation.
By Todd Mullins and Carrie Mobley on Energy EnforcementThe Federal Energy Regulatory Commission (FERC) Office of Enforcement (OE) has historically focused on four “priorities,” as described in its annual Report on Enforcement. Those four priorities included (1) fraud and market manipulation; (2) serious violations of Reliability Standards; (3) anticompetitive conduct; and (4) conduct that threatens the transparency of regulated markets. In the 2021… Continue Reading
By Todd Mullins and Katlyn A. Davis Farrell on Compliance,Energy EnforcementEntities registered with the North American Electric Reliability Corporation (NERC) to comply with mandatory electric reliability standards (Reliability Standards) or face civil penalties should take note of an order issued by the Federal Energy Regulatory Commission (FERC) on January 23, 2020 in Docket No. RR19-7-000 (January 23 Order). In the January 23 Order, FERC, which oversees NERC… Continue Reading
By Todd Mullins on Energy EnforcementThis week, the Federal Energy Regulatory Commission (“FERC”) issued an order rescinding its Notice of Alleged Violation (“NAV”) Policy. The NAV Policy was put in place by a 2009 order and authorized FERC’s Office of Enforcement Staff (“OE staff”) to ask the FERC Secretary to issue a public NAV at the stage of the investigation… Continue Reading
By Todd Mullins on Energy EnforcementThis post recently appeared in Law360, available for subscribers here. Anyone practicing in the Federal Energy Regulatory Commission enforcement arena should sit up and take notice of the recent developments in the Footprint case at FERC. The most public step in an enforcement procedure before FERC is the issuance of an order to show cause,… Continue Reading