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Inflation Reduction Act
PJM IBTs - What Is Going On?
There is another development in the PJM Internal Bilateral Transactions (IBT) saga. PJM appears to have indirectly threatened to investigate parties that seek to comment on and help resolve the generic issues raised by PJM's interpretation of its tariff and...
2012 Wealth Transfer Tax Laws: The Window of Opportunity is Rapidly Closing
The window of opportunity to take advantage of the currently applicable wealth transfer tax laws is rapidly closing, and once shut, it is possible that we may never see such generous estate planning opportunities again. The unique estate planning opportunities...
Ohio Issues Emergency Rules on Underground Injection Control Activities, Effective Immediately
Companies that own and operate Class II disposal wells in Ohio will now have to comply with tougher standards when using deep injection wells for the underground disposal of brine and other wastes, a regulatory change spurred by findings that...
Dual Air Permitting Scheme in Texas Lives On, For Now
The D.C. Circuit Court of Appeals' ruling on June 26, 2012, upholding the EPA's various rulemakings regulating greenhouse gases (GHG) is a significant blow to the numerous oil and gas, electric generating, chemical, and refining companies operating in Texas that...
TCEQ "Compliance History" Rule Change to Affect Regulated Facilities in Texas
At the direction of the Texas Legislature, the Texas Commission on Environmental Quality (TCEQ) has for the last decade provided "compliance history" regulations that generate a score for each regulated facility in the state based generally on the number and...
UPDATE: PJM Provides Its View
Internal Bilateral Transactions: Regulatory Risk & Confusion Reign As explained in our alert "
Internal Bilateral Transactions: Regulatory Risk & Confusion Reign
Internal Bilateral Transactions (IBTs) are bilateral transactions occurring between market participants within a Regional Transmission Organization (RTO) market. While these transactions have differing names in various RTOs ( IBTs in PJM, ISO-NE, and NYISO; Financial Schedules in MISO; Inter-SC Trades...
Electricity Buy/Sells: Permitted, Prohibited, or Simultaneous Exchanges?
Recently the Federal Energy Regulatory Commission clarified the regulatory status of a type of energy transaction called a "Simultaneous Exchange." However, at the same time, the Commission has created ambiguity in a related area. That is, whether electricity Buy/Sell transactions...
Priority Access on Interconnection Lines: FERC's Policy Under Review
The Federal Energy Regulatory Commission recently issued a Notice of Inquiry seeking comment on whether and/or how FERC should revise its current policy concerning priority rights on interconnection lines that connect generators to the larger transmission grid. Comments are due...
Department of Labor's OFCCP Postpones TRICARE Network Provider Compliance Reviews
The U.S. Department of Labor, Office of Federal Contract Compliance Programs (OFCCP), the federal agency tasked with enforcing the affirmative action requirements of Executive Order 11246 and related federal statutes, is notifying TRICARE network providers that any on-going compliance reviews...
Extensive New Disclosure Requirements for Underwriters of Municipal Securities Take Effect August 2, 2012
Underwriters of municipal securities will be required to make extensive new disclosures in writing to issuers of municipal securities beginning August 2, 2012 under an interpretation of Municipal Securities Rulemaking Board Rule G-17 (the Notice) 1 approved by the Securities...
Judge Reverses Own Decision to Extend the Texas Sales Tax Manufacturing Exemption to Include Oil and Gas Extraction Equipment
On April 11, 2012, Judge John Dietz issued a ruling from the bench in Southwest Royalties, Inc. v. Combs , Case D-1-GNU-09-004282 (Travis County 250th Dist. Ct.) to extend the Texas sales tax exemption for manufacturing property to include certain...
Texas Ruling Could Expand the Scope of the Manufacturing Exemption from Sales or Use Tax to Equipment Used in Oil and Gas Extraction
In a recent Texas bench ruling, in the case of Southwest Royalties, Inc. v. Combs , Case D-1-GNU-09-004282 (Travis County 250th Dist. Ct.), the court expanded the Texas sales or use tax exemption for manufacturing property to include certain items...
Companies File Rehearing Requests on PJM Western Hub IBT Issue
As previously noted in an Energy Legal Blog post on March 19 , in an order resolving a complaint filed by DC Energy, LLC and DC Energy Mid"Atlantic, LLC against PJM Interconnection LLC (PJM), the Federal Energy Regulatory Commission (FERC)...
Employer Safety Incentive Programs Might be Unlawful - New OSHA Memo Clarifies, Threatens
Employers who reward employees through certain kinds of safety incentive programs for the absence, or limited number, of workplace injuries might be violating OSHA's anti-retaliation and recordkeeping rules, according to a March 12, 2012, Guidance Memorandum issued by the agency...