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FERC Extends Certain Filing Deadlines for Those Affected by Hurricanes

On September 11, 2017, FERC granted a one-month extension for utilities and others affected by Hurricanes Harvey and Irma to submit certain filings. The extension applies to:

  • FERC-required form submissions,

  • nonstatutory filings such as compliance filings and deficiency letter responses, and

  • filings required by FERC jurisdictional tariffs.

For those filings, entities affected by the hurricanes need not file until after October 11, 2017.

Critically, the extension does not apply to those filings with deadlines imposed by statute. For entities whose filings are not covered by the extension, FERC's order notes that they may seek individual extensions of time where permitted under the applicable statute.

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About this Author

J. Daniel Skees, Electric Utilities Attorney, Morgan Lewis, Law Firm

J. Daniel Skees represents electric utilities before the Federal Energy Regulatory Commission (FERC) and other agencies on rate, regulatory, and transaction matters. He handles rate and tariff proceedings, electric utility and holding company transactions, reliability standards development and compliance, and FERC rulemaking proceedings. The mandatory electric reliability standards under Section 215 of the Federal Power Act are a major focus of Dan’s practice. He advises clients regarding compliance with reliability standards, and helps them participate in the development of new standards...


Stephen M. Spina is a partner in Morgan Lewis's Energy Practice. Mr. Spina represents electric utilities and other electric industry participants before the Federal Energy Regulatory Commission (FERC) on a variety of matters, including industry restructuring, market investigations, and regulatory issues under the Federal Power Act.