Client Alert

| April 22, 2010

FERC Changes Course Again and Suspends Civil Penalty Guidelines

The Federal Energy Regulatory Commission (FERC) on April 15, 2010, changed course again and suspended the operation of its recently announced Policy Statement on Civil Penalty Guidelines. FERC previously had declined numerous requests to issue Penalty Guidelines. The Penalty Guidelines had been announced in a Policy Statement on March 18, 2010 and were described in an earlier Dewey & LeBoeuf Client Alert.

For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:

Lawrence G. Acker

+1 202 346 8016

James F. Bowe, Jr.

+1 202 346 7999

Elias G. Farrah

+1 202 346 8013

Hugh E. Hilliard

+1 202 346 7962

Catherine P. McCarthy

+1 202 346 8753

Charles A. Moore

+1 713 287 2086

Brian D. O'Neill

+1 202 346 8012

David R. Poe

+1 202 346 8039

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383