On Aug. 1, 2016, the Council on Environmental Quality (CEQ) issued its Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate
Continue Reading CEQ Issues Measured Final Guidance for Federal Agencies in their Consideration of GHG Emissions in NEPA Reviews

Francesca Ciliberti-Ayres‡
Francesca focuses her practice on energy regulatory and litigation matters before the Federal Energy Regulatory Commission (FERC), state public utility commissions, and the Court of Appeals. Her experience includes representing parties in major interstate natural gas and petroleum pipeline hearings involving complex multiparty major rate cases, in certificate proceedings and confidential investigations before FERC involving natural gas, oil, and environmental matters, LNG licensing, tariff, and fuel proceedings. She also advises clients on ensuring compliance with regulatory requirements and environmental regulations.
FERC Assesses Penalties for Alleged No-Risk UTC Trading Against City Power and Its Founder
Earlier this month, the Federal Energy Regulatory Commission (FERC) issued an Order Assessing Civil Penalties against City Power Marketing, LLC (City Power) and its founder and sole owner, K. Stephen…
Continue Reading FERC Assesses Penalties for Alleged No-Risk UTC Trading Against City Power and Its Founder
Performance Enhancement: FERC Approves Significant Restructuring of PJM’s Capacity Market
On June 9, 2015, theFederal Energy Regulatory Commission (FERC) conditionally approved significant reforms to PJM’s capacity market, implementing the Capacity Performance Resource product, with PJM’s compliance filing due within 30…
Continue Reading Performance Enhancement: FERC Approves Significant Restructuring of PJM’s Capacity Market
Performance Enhancement: FERC Approves Significant Restructuring of PJM’s Capacity Market
On June 9, 2015, the Federal Energy Regulatory Commission (FERC) conditionally approved significant reforms to PJM’s capacity market, implementing the Capacity Performance Resource product, with PJM’s compliance filing due within…
Continue Reading Performance Enhancement: FERC Approves Significant Restructuring of PJM’s Capacity Market
May 2015 Brings a Crop of FERC ‘Loophole’ Manipulation Civil Penalty Assessments
In May, two “loophole” penalty orders were issued regarding recent fraud and manipulation investigations conducted by the Federal Energy Regulatory Commission’s (FERC) Office of Enforcement (OE), which are discussed below.
Continue Reading May 2015 Brings a Crop of FERC ‘Loophole’ Manipulation Civil Penalty Assessments