Fifth Circuit Limits PURPA Wind Sales

On September 8, 2014, the federal Fifth Circuit Court of Appeals issued an opinion that may make it more difficult for certain qualifying facilities (QFs) to sell power to electric utilities.  The two-judge majority concluded that wind generation facilities owned by Exelon could not sell power pursuant to a “legally enforceable obligation” to Southwestern Public Service Corp.  A legally enforceable obligation essentially means that the utility has a legal obligation to purchase power from the QF.  The third judge issued a strongly worded dissent disagreeing with the majority’s holding and reasoning. 

FERC Requires Utilities to Pay QFs for Capacity

On March 20, 2014, the Federal Energy Regulatory Commission (FERC) issued a declaratory order concluding that utilities must pay qualifying facilities (QF) for capacity as well as energy in sales pursuant to a legally enforceable obligation.  A legally enforceable obligation is when a QF has the right to sell power to a utility at specific prices.  FERC found that the Montana Public Service Commission’s (Montana Commission) rule requiring QFs to participate in a competitive bidding process to be paid for capacity failed to adequately compensate QFs.  As it typically does, FERC declined to initiate an enforcement action against the Montana Commission, but the declaratory order allows a number of QFs to sue the commission in court.