Client Alert

| July 26, 2010

FERC Establishes New Restrictions on Non-Jurisdictional Pipelines

In an order responding to a request for approval of a transaction between Arizona Public Service Company (APS) and Sequent Energy Management, L.P. (Sequent), Arizona Public Service Co., 132 FERC 61,064 (2010), FERC expanded its prohibitions on buy sell transactions to include not only transportation on open access interstate pipelines, but also transportation by intrastate pipeline operating under Natural Gas Policy Act (NGPA) section 311 and by Hinshaw pipelines providing transportation under blanket certificates.

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

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