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Updated Section 3610 Guidance

Client Alert | less than 1 min read | 05.01.20

Agencies continue to release and refine Section 3610 billing guidelines. There continue to be substantive differences between agencies, creating compliance challenges for contractors. Crowell & Moring continues to track the latest Section 3610 billing guidance. Click here to view the updated table, current as of May 1, 2020.

Insights

Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...