Emera Maine v. Federal Energy Regulatory Commission

854 F.3d 662, 2017 WL 1379512, 2017 U.S. App. LEXIS 6551
CourtCourt of Appeals for the D.C. Circuit
DecidedApril 18, 2017
Docket15-1139 Consolidated with 15-1141
StatusPublished
Cited by1 cases

This text of 854 F.3d 662 (Emera Maine v. Federal Energy Regulatory Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emera Maine v. Federal Energy Regulatory Commission, 854 F.3d 662, 2017 WL 1379512, 2017 U.S. App. LEXIS 6551 (D.C. Cir. 2017).

Opinion

WILKINS, Circuit Judge:

We consider two petitions for review challenging determinations by the Federal Energy Regulatory Commission (“FERC” or “the Commission”) following compliance Slings by the regional transmission organization for New England’s electric grid. See ISO New England Inc., Order on Compliance Filings, 143 F.E.R.C. ¶ 61,150 (May 17, 2013) (Initial Order), on reh’g, 150 F.E.R.C. ¶ 61,209 (Oct. 16, 2014) (Rehearing Order).

For the reasons given below, both petitions for review are denied.

I.

In 2011, the Commission issued Order No. 1000, ordering utilities to remove certain “right of first refusal” provisions from their existing tariffs and agreements. See Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, F.E.R.C. Stats. & Regs. ¶ 31,323, 76 Fed. Reg. 49,842 (2011) [hereinafter Order No. 1000]. These provisions granted incumbent utilities “the option to construct any new transmission facilities in their particular service areas, even if the proposal for new construction came from a third party.” S.C. Pub. Serv. Auth. v. FERC (South Carolina), 762 F.3d 41, 72 (D.C. Cir. 2014) (per curiam). Order No. 1000’s prohibition of such provisions was premised on the rationale that rights of first réfusal deterred new entrants “from proposing much-needed infrastructure reforms, discouraging competition within the industry, and potentially driving up the cost of rates charged for wholesale electricity service.” Okla. Gas & Elec. Co. v. FERC (Oklahoma Gas), 827 F.3d 75, 76 (D.C. Cir. 2016).

Order No. 1000 was upheld by this Court in South Carolina, 762 F.3d at 71-81. The petitioners in that case raised a litany of challenges to the Order, including that FERC was prevented from eliminating rights of first refusal because those provisions were entitled to the Mobile-Sierra presumption. Id. at 81. The Mobile-Sierra presumption requires the Commission to “presume a contract rate for wholesale energy is just and reasonable” and prohibits the Commission from setting aside that rate unless . the Commission finds that the rate “seriously harm[s] the public interest.” 1 Id.; see generally United *666 Gas Pipe Line Co. v. Mobile Gas Serv. Corp. (Mobile), 350 U.S. 332, 76 S.Ct. 373, 100 L.Ed. 373 (1956); Fed. Power Comm’n v. Sierra Pac. Power Co. (Sierra), 350 U.S. 348, 76 S.Ct. 368, 100 L.Ed. 388 (1956). It is premised on the idea that arms-length bargaining generally results in contract rates that are just and reasonable. See NRG Power Mktg., LLC v. Me. Pub. Utils. Comm’n, 558 U.S. 165, 175 n.4, 130 S.Ct. 693, 175 L.Ed.2d 642 (2010).

In Order No. 1000, “[t]he Commission had reserved judgment on whether to apply this presumption to the rights of first refusal until evaluating the individual utilities’ compliance filings, and therefore so did we.” Oklahoma Gas, 827 F.3d at 76 (citing South Carolina, 762 F.3d at 81).

Oklahoma Gas presented the situation South Carolina anticipated and we considered a petition for review of a FERC compliance filing determination in which FERC refused to apply the Mobile-Sierra presumption to a right of first refusal provision. We held that the Mobile-Sierra presumption was inapplicable because the presumption does not extend to “terms arrived at by horizontal competitors with a common interest to exclude any future competition.” Id. at 80.

The case before us now presents a slight wrinkle on the question we answered in Oklahoma Gas, along with a separate challenge to an application of another provision of Order No. 1000.

In response to Order No. 1000, a compliance filing was made by ISO New England Inc. (“ISO-NE”) — the FERC-approved regional transmission organization whose tariff governs transmission service and wholesale electric markets in New England — and its participating transmission owners (the “Transmission Owners”). After FERC issued the Initial Order and Rehearing Order containing FERC’s compliance determinations, two petitions for review were filed with this Court. •

The first petition for review was filed by the Transmission Owners, who object to FERC’s determination that the right of first refusal must be removed from the Transmission Operating Agreement among ISO-NE and the Transmission Owners. What makes this case different from Oklahoma Gas is that, here, FERC purported to apply the Mobile-Sierra presumption as a matter of discretion, even though FERC continued to maintain that it was not required to apply the presumption as a matter of law (a position we vindicated in Oklahoma Gas). As a result, we must consider the new question of whether FERC has overcome the Mobile-Sierra presumption, which presents a higher hurdle than the more deferential default standard for evaluating FERC actions.

The second petition for review was filed by the New England States Committee on Energy, Inc. (“NESCOE”) and governmental entities from five of the six states it represents in regional electricity matters: Connecticut, Massachusetts, New Hampshire, Rhode Island, and Vermont (collectively, with NESCOE, the “State Petitioners”). The State Petitioners argue that, in the ISO-NE compliance order, the Commission went beyond Order No. 1000 and impermissibly altered the balance of responsibility and power as between state governments and ISO-NE.

II.

We consider first the petition for review filed by the Transmission Owners.

In its orders, the Commission determined that the Mobile-Sierra presumption did not apply as a matter of law. See Initial Order ¶¶ 160-72. Nevertheless, as a matter of discretion, the Commission applied the *667 presumption to the right of first refusal provision in Section 3.09 of the Transmission Operating Agreement, noting that it had earlier accorded Mobile-Sierra protection to the provision in 2004 when the Transmission Operating Agreement was first approved. See id. ¶ 172. However, the Commission ultimately found that the right of first refusal “severely harm[s] the public interest,” meaning that the Mobile-Sierra presumption was overcome. Id.

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Cite This Page — Counsel Stack

Bluebook (online)
854 F.3d 662, 2017 WL 1379512, 2017 U.S. App. LEXIS 6551, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emera-maine-v-federal-energy-regulatory-commission-cadc-2017.