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PURPA Rules: FERC Revisions Regarding QF Power Sales, Requirements for Utilities, QF Certification, State Authority

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, April 18, 2024

Recorded event now available

or call 1-800-926-7926

This CLE course will provide energy counsel with an in-depth analysis of PURPA regulations, FERC's revisions, and recent court decisions. The panel will discuss critical aspects of the revised rules to encourage the development of qualifying small power production facilities and cogeneration facilities (QFs), requirements for electric utilities, state authority for energy rates in QF power sales contracts, and modification of the "one-mile rule." The panel will also discuss changes to a utility's obligation to purchase QF output, QF certifications, and other vital provisions.


PURPA, as implemented through FERC regulations, requires electric utilities to interconnect with QFs, purchase electricity from certain QFs, and provide backup energy to QFs at just, reasonable, and not unduly discriminatory rates and terms. PURPA also provides exemptions for certain QFs from numerous provisions of the Federal Power Act, the Public Utility Holding Company Act of 2005, and certain state laws and regulations.

FERC's PURPA regulations address: (1) avoided cost determinations for QF rates; (2) treatment of QF facilities located at the same site through a restructuring of the "one-mile rule;" (3) mandatory purchase obligations from QFs; (4) contracts and legally enforceable obligations (LEOs); and (5) QF certification, including self-certification and self-recertification. These sweeping revisions have caused both controversy and confusion. Energy counsel must understand the application of these rules and identify critical issues for certain facilities, developers, lenders, and operators.

Listen as our panel discusses vital aspects of the revised rules, requirements for electric utilities, changes to state authority to set QF rates, the "one-mile rule," QF certification, and other key issues.



  1. PURPA regulations
    1. Old vs. current rules
    2. FERC revisions
  2. Impact to QFs
    1. State authority to set QF rates
    2. Legally enforceable obligation to purchase QF output
    3. The "one-mile rule"
  3. QF certification
  4. Next steps and best practices for energy counsel


The panel will review these and other key issues:

  • What are the key differences between the old vs. current PURPA regulations?
  • What revisions were made by FERC regarding the enforcement of the PURPA regulations?
  • What is the impact of these regulations on facilities?
  • What challenges result from the rules for QFs?
  • What authority has been granted to states under the revised regulations?
  • How do the revised regulations restructure the "one-mile rule"?
  • What is the impact on challenging QF certifications and recertifications?


Christensen, Eric
Eric L. Christensen

Beveridge & Diamond

Mr. Christensen is one of the Pacific Northwest’s leading energy and natural resources attorneys. His practice...  |  Read More

Johnson, Scott
Scott Daniel Johnson

Senior Counsel

Mr. Johnson's practice focuses on energy regulation and renewable energy.

 |  Read More
Norfolk, Ryan
Ryan C. Norfolk

Special Counsel
Baker Botts

Mr. Norfolk provides regulatory guidance on state and federal regulatory issues arising from the disposition and...  |  Read More

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