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Inflation Reduction Act
PHMSA Proposes Plans to Revise Volatility Standard for the Transport of Crude Oil
Today, PHMSA released an advanced notice of proposed rulemaking (ANPRM), announcing that it is considering revising the Hazardous Materials Regulations (HMR) to establish vapor pressure limits for the transportation of crude oil and potentially all Class 3 flammable liquid hazardous...
U.S. Futures Exchanges Disciplinary Actions Report - December 2016
NYMEX NYMEX 16-0530-BC Position Limits Violation of Rule 562 – Position Limit Violations. At the close of business on a single day in September 2016, a member firm held a short position which was 38.4% over the standard expiration month...
Obama Bans Drilling Offshore Atlantic, Arctic – But For How Long?
With a new President on the White House doorstep, President Obama has announced a ban – ostensibly permanent – on offshore oil and gas drilling in federal waters along the Eastern seaboard and offshore Alaska. President Obama appears to be...
U.S. Futures Exchanges Disciplinary Actions Report - November 2016
COMEX COMEX 14-0050-BC Disruptive Trading Violation of Rule 575.A and Rule 575.D – Disruptive Practices Prohibited. Between November 2014 and March 2015, a member trader, with no intent to trade, entered or layered orders in futures contracts in order to...
Adverse Possession in the Oil Patch
The most basic example of adverse possession is when a landowner fences in land that belongs to a neighbor. This is trespassing, but if a long enough period of time passes without the neighbor bringing a trespass claim, the trespasser...
U.S. Futures Exchanges Disciplinary Actions Report - October 2016
NYMEX NYMEX 13-9490-BC-1 COMEX 13-9490-BC-1 Disruptive Trading Violation of Rule 432– General Offenses (in part); Rule 433 – Strict Liability for the Acts of Agents. Between March and July 2013, two traders, acting on behalf of a member firm, engaged...
2016 Election: Outlook for the Clean Power Plan and Other Environmental Issues
Scott Segal, co-head of Bracewell’s Policy Resolution Group, and Jeff Holmstead, head of the Environmental Strategies Group at Bracewell, discuss how the next President and Congress will confront issues such as climate change, the Clean Power Plan, and other environmental...
2016 Election: Outlook for Energy Policy
Dee Martin, co-head of Bracewell’s Policy Resolution Group, and Salo Zelermyer, a partner in Bracewell’s Policy Resolution Group, discuss what the results of the election may mean for oil and gas, renewable energy, and fuels. [video]
Federal Report Identifies New Criteria for Underground Gas Storage Facilities
On October 19, a federal task force released a Final Report outlining recommendations for industry and government in the wake of the 2015 natural gas leak at Aliso Canyon in southern California. The Interagency Task Force on Natural Gas Storage...
U.S. Futures Exchanges Disciplinary Actions Report - September 2016
NYMEX NYMEX 16-0355-BC EFRP Violation of Rule 432.X – General Offenses. In June 2015 a member company executed two EFRP transactions on two dates with the intent that they be block trades. Because there were no corresponding related positions, the...
PHMSA Releases Civil Penalty Policy Framework, Sets its Sight on Higher Penalties “Across the Board”
This week, the Pipeline and Hazardous Materials Safety Administration (PHMSA) released a General Policy Statement announcing its intent to make available to the public a Civil Penalty Policy Framework. Previously only available by request, the civil penalty framework provides insight...
PSA and Allocation Wells – The Current State of Play
The Railroad Commission of Texas (the “RRC”) routinely grants drilling permits to operators seeking to drill horizontal wells across multiple leased tracts (or existing pooled units) that are not formally “pooled” together under the pooling clauses in the applicable underlying...
Court Clarifies Standard For CFTC Price-Based Manipulation Charge
On September 30, 2016, the United States District Court for the Southern District of New York issued an order in CFTC vs Wilson, et. al , 13 Civ. 7884 (NYSD), denying motions for summary judgment in an action by the...
FERC Proposes Clarifications to EQR Requirements
In its September 22 Open Meeting, the Federal Energy Regulatory Commission (Commission) issued a Notice Seeking Comments on Proposed Revisions to Electric Quarterly Report Reporting Requirements (in Docket No. RM01-8-000, et al. ) as part of an ongoing effort to...
U.S. Futures Exchanges Disciplinary Actions Report - August 2016
ICE 2015-051 Block Trades Violation of Rule 6.08(b)(i) - Order Ticket Requirements, Rule 4.07(c) - Block Trading, and Rule 4.01 - Duty to Supervise. On multiple occasions, an entity allegedly failed to comply with the recordkeeping requirements when handling customer...