All Civil Penalty Actions - 2026

To access the significant orders and federal district court papers related to all matters that have proceeded to Orders to Show Cause, see the Orders to Show Cause Proceedings page.

Subject(s) of Investigation and Order Sanctions, including Civil Penalties, Disgorgement, and Compliance Measures Description of Findings of Violations
Interstate Power and Light Company, Docket No. IN25‑6‑000, Order Approving Stipulation and Consent Agreement, 195 FERC ¶ 61,048 (Apr. 17, 2026) Interstate neither admitted nor denied the violations but agreed to pay a civil penalty of $70,000 to the United States Treasury and to comply with specified monitoring provisions.  As part of the settlement, Interstate will submit annual compliance monitoring reports to Enforcement for two years, with the option for a third year. The Commission approved the Stipulation and Consent Agreement (Agreement) between the Office of Enforcement and Regulatory Accounting and Interstate Power and Light Company. As set forth in the Agreement, Enforcement determined that during the Relevant Period Alliant Energy Corporate Services, Inc. (AECS), acting on behalf of Interstate Power and Light Company, violated Commission regulations by: (a) misrepresenting to Potomac Economics the operational status of the Marshalltown Combustion Turbine (MTown CT) during a routine audit; (b) providing false statements regarding the causes and timing of outages at MTown CT Unit 1 and MTown CT Unit 3; (c) submitting inaccurate information in AECS’s initial Audit Response; and (d) failing to exercise due diligence to ensure the accuracy of communications with a Commission‑approved market monitor, resulting in the assessment of Capacity Replacement Non‑Compliance Charges on Interstate Power and Light Company.

American Efficient, LLC; Modern Energy Group LLC; MIH LLC; Midcontinent Energy LLC; Wylan Energy, L.L.C.; Affirmed Energy LLC

Prior Commission Activity: Order Assessing Civil Penalties, 195 FERC ¶ 61,043 (Apr. 15, 2026); Order to Show Cause and Notice of Proposed Penalty, 189 FERC ¶ 61,196 (Dec. 16, 2024)		 Disgorgement of $2,084,828, plus interest, to MISO; disgorgement of $407,732,930, plus interest, to PJM; civil penalty in the amount of $722,000,000. The Commission issued an Order Assessing Penalties on April 15, 2026, against American Efficient, LLC, its various subsidiary companies, and its corporate parents, ordering the subjects to pay (1) disgorgement in the amount of $2,084,828, plus interest, to MISO; (2) disgorgement in the amount of $407,732,930, plus interest, to PJM; and (3) a civil penalty in the sum of $722,000,000.  The Order finds that American Efficient (i) violated Section 222 of the Federal Power Act, 16 U.S.C. § 824v, and the Commission’s Anti-Manipulation Rule, 18 C.F.R. § 1c.2, through a manipulative scheme and course of business in PJM and MISO that extracted millions of dollars in capacity payments for a purported energy efficiency project that did not actually cause reductions in energy use; and (ii) violated the PJM and MISO tariffs by participating in those markets as an Energy Efficiency Resource (“EER”), despite not satisfying the tariff requirements to participate as an EER.

MPH Rockaway Peakers, LLC and Bayswater Peaking Facility, LLC (Rockaway), Docket No. IN25-10-000, Order Approving Stipulation and Consent Agreement, 195 FERC ¶ 61,019 (April 8, 2026)

 Rockaway admitted the violations and agreed to total civil penalties of $185,000 and disgorgement of $626,642 in capacity and reserve market overpayments.  Rockaway had previously disgorged $299,298 and paid $149,649 in sanctions to NYISO pursuant to NYISO Tariff section 5.12.12.2, which permits NYISO to impose sanctions and penalties for certain capacity market violations.  Rockaway will (a) pay a civil penalty of $35,351 to the United States Treasury, which takes into consideration credit for the NYISO sanctions it has already paid, (b) disgorge a balance of $327,344 plus interest to NYISO; and submit two annual compliance monitoring reports to OERA, with the requirement of a third annual report at OERA’s option. The Commission approved the Stipulation and Consent Agreement (Agreement) between the Office of Enforcement and Regulatory Accounting (OERA) and Rockaway.  As set forth in the Agreement, OERA determined that from November 2020 to September 2023 (Relevant Period) Rockaway violated the NYISO Tariff and Commission regulations by, (a) conducting summer capability tests in configurations that differ from expected operations; (b) not informing NYISO of derates; (c) submitting inaccurate Generating Availability Data System (GADS) data; and (d) overselling capacity and reserves from its Far Rockaway GT1 peaking unit (GT1).
Terra-Gen, LLC, Docket No. IN26-2-000, Order Approving Stipulation and Consent Agreement, 195 FERC ¶ 61,016 (April 7, 2026) Civil penalty of $4,950,000; disgorgement of $681,007 plus interest to CAISO; and compliance monitoring

The Commission approved a Stipulation and Consent Agreement (Agreement) between the Office of Enforcement and Regulatory Accounting (Enforcement) and Terra-Gen, LLC (Terra-Gen).  The Agreement resolves Enforcement’s investigation into whether Terra-Gen violated the California Independent System Operator (CAISO) Open Access Transmission Tariff (Tariff), the Commission’s Market Behavior Rule (18 C.F.R. § 35.41(a)), section 222 of the Federal Power Act (16 U.S.C. § 824v), and the Commission’s Anti-Manipulation Rule (18 C.F.R. § 1.c.2) in connection with Terra-Gen’s participation in the CAISO ancillary services market from July 7, 2020 through April 17, 2022.  Enforcement investigated whether Terra-Gen selectively avoided CAISO regulation-down awards at its Mojave 89 and Mojave 90 resources by disconnecting these resources from automatic generation control and/or claiming unjustified outages.  Additionally, Enforcement investigated whether Terra-Gen also violated the Commission’s Duty of Candor Rule (18 C.F.R. § 35.41(b)) in connection with a compliance report that it submitted to Enforcement pursuant to a prior Commission-approved settlement of an unrelated matter.

 

Terra-Gen stipulates to the facts set forth in Section II of the Agreement, and admits all violations alleged in Section III of the Agreement except for violation of section 222 of the Federal Power Act and the Anti-Manipulation Rule, which Terra-Gen neither admits nor denies.  Terra-Gen agrees to: (a) pay a civil penalty of $4,950,000 to the United States Treasury; (b) disgorge $681,007, plus interest, to CAISO; and (c) be subject to compliance monitoring and reporting requirements for two years, with the requirement of a third year at Enforcement’s discretion.
Tenaska Power Services Co., Docket No. IN25-13-000, Order Approving Stipulation and Consent Agreement, 194 FERC ¶ 61,029 (Jan. 12, 2026) Civil penalty of $51,000; disgorgement of $78,354 plus interest to ISO-NE; and compliance monitoring.

The Commission approved the Stipulation and Consent Agreement (Agreement) between the Office of Enforcement and Regulatory Accounting (Enforcement) and Tenaska Power Services Co. (TPS).  The Agreement resolves Enforcement’s investigation into whether TPS violated the ISO-NE Transmission, Markets, and Services Tariff and the Commission’s market behavior rules, 18 C.F.R. §§ 35.41(a) and (b), by failing to properly offer generation from the Berkshire power facility in Agawam, Massachusetts from January 11-12, 2021.

TPS stipulates to the facts set forth in Section II of the Agreement, and neither admits nor denies the alleged violations in Section III of the Agreement.  TPS agrees to: (a) pay a civil penalty of $51,000 to the United States Treasury; (b) pay disgorgement of $78,354.00, plus interest, to ISO-NE; (c) be subject to compliance monitoring as described in the Agreement.
Green Mountain Power Corp., Docket No. IN25-15-000, Order Approving Stipulation and Consent Agreement, 194 FERC ¶ 61,014 (Jan. 6, 2026) Civil penalty of $32,500; disgorgement of $94,833.26, plus interest to ISO-NE; and compliance monitoring.

The Commission approved a Stipulation and Consent Agreement (Agreement) between the Office of Enforcement and Regulatory Accounting (Enforcement) and Green Mountain Power Corporation (Green Mountain).  The Agreement resolves Enforcement’s investigation into whether Green Mountain violated the ISO-NE Transmission, Markets, and Services Tariff and the Commission’s Market Behavior Rules, 18 C.F.R. § 35.41 (2025), by failing to properly report outages at the Bolton Falls Dam project, between September 27, 2022 and December 27, 2024.

Green Mountain stipulates to the facts set forth in Section II of the Agreement, and admits the violations alleged in Section III of the Agreement.  Green Mountain agrees to: (a) pay a civil penalty of $32,500 to the United States Treasury; (b) pay disgorgement of $94,833.26, plus interest, to ISO-NE; (c) submit two annual compliance monitoring reports to Enforcement, with the requirement of a third annual report at Enforcement’s option; and (d) conduct annual training for three consecutive years on compliance with applicable ISO-NE market rules—including but not limited to outage reporting requirements.   

Total Civil Penalties assessed for all years 2007 to present: $905,481,604.

Total Civil Penalties does not include the $30,000,000 assessed in Hunter and overturned on jurisdictional grounds by the U.S. Court of Appeals for the District of Columbia Circuit.  Total Civil Penalties against BP America Inc., et al. (Docket No. IN13-15) includes only the 2023 Commission-approved settlement amount of $10,750,000.  Total Civil Penalties does not include penalties proposed or assessed in the following currently pending matters:  $15,000,000 civil penalty assessed against Boyce Hydro Power LLC; or $20,160,000 civil penalty proposed against Rover Pipeline Company, LLC and Energy Transfer Partners, L.P. (Docket No. IN19-4-000); or $40,000,000 civil penalty proposed against Rover Pipeline Company, LLC and Energy Transfer Partners, L.P. (Docket No. IN17-4-000); or $25,000,000 civil penalty assessed against Ketchup Caddy, LLC and $1,500,000 civil penalty assessed against Philip Mango; or $722,000,000 civil penalty assessed against American Efficient, LLC et al.

Total Disgorgement ordered for all years 2007 to present: $665,684,123.

Total Disgorgement does not include the amount ordered in the following currently pending matters:  $506,502 assessed against Philip Mango and $409,817,758 assessed against American Efficient, LLC et al.

Total Other Payments ordered for all years 2007 to present: $188,180,573.

“Other payments” are defined as miscellaneous items ordered by the Commission that have a financial value, but are not considered a civil penalty or disgorgement. They include payments towards mitigation, enhancements, compliance activities, or a hurricane charitable fund. Payments included in this total are: $1,000,000 charitable donation ordered in Entergy Energy Services, Inc. in 2007; $1,000,000 in compliance plan improvements ordered in Duquesne Light Company in 2008; $2,000,000 in compliance plan improvements ordered in Edison Mission in 2008; $2,000,000 in mitigation and compliance plan improvements ordered in Grand River Dam Authority in 2011; $2,200,000 in public safety enhancements and computer system upgrades ordered in Erie Boulevard Hydropower, L.P. and Brookfield Power US Assets Management, LLC in 2014; $179,600,573 judgment in favor of PJM in a Texas state court in GreenHat Energy, LLC in 2022; $350,000 in compliance plan improvements ordered in ISO-New England, Inc. in 2022.

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This page was last updated on April 23, 2026