Cadwalader attorneys reviewed an advance notice of proposed rulemaking ("ANOPR") by the Federal Energy Regulatory Commission ("FERC") that would revise (1) FERC's policies for evaluating oil pipeline indexed rate changes, and (2) the reporting requirements of FERC Form No. 6 ("Annual Report of Oil Pipeline Companies"). The notice was issued for public comment to "all interested persons."
The attorneys concluded that the ANOPR might prove to be another substantial step by FERC toward enhancing transparency in the utility rate-setting and rate-reviewing processes.
Initial comments are due within 45 days after the ANOPR's publication in the Federal Register, and replies to comments are due within 90 days after publication.
Click here to view the Cadwalader memorandum authored by Mark Haskell, Lamiya Rahman and Brett Snyder.
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