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

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

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Conducted on Thursday, October 22, 2020

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Course Materials

This CLE course will provide energy counsel an in-depth analysis of FERC's recent, expansive revisions to its PURPA regulations. The panel will discuss key aspects of the revised rules to encourage the development of QFs, new 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 from a QF, QF certifications, and other key provisions.


On July 16, 2020, FERC adopted significant revisions to its PURPA regulations that will impact qualifying small power production facilities and cogeneration facilities (QFs).

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 new 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) new 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 key issues for certain facilities, developers, lenders, and operators.

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



  1. New PURPA regulations
    1. Old vs. new rule
    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. new PURPA regulations?
  • What revisions were made by FERC regarding the enforcement of the new PURPA regulations?
  • What is the impact of these new regulations to facilities?
  • What challenges result from the new regulations for QFs?
  • What authority has been granted to states under the new regulations?
  • How do the regulations restructure the "one-mile rule"?
  • What is the impact to challenging QF certifications and recertifications?


Christensen, Eric
Eric L. Christensen

Of Counsel
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

Akin Gump Strauss Hauer & Feld

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

 |  Read More
Norfolk, Ryan
Ryan C. Norfolk

Of Counsel
Winston & Strawn

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

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