FERC Reaffirms Need for QFs to File Recertification

February 26, 2026

On February 19, the Federal Energy Regulatory Commission (“FERC”) issued an order (“Branch Street Order”) reaffirming that a qualifying facility (“QFs”) must submit a recertification when there is a material change in the upstream ownership information the QF previously reported in its Form No. 556, and that failure to do so will result in a loss of QF status. The Branch Street Order largely reflects FERC’s application of its 2022 decision in Irradiant Partners, LP, 178 FERC ¶ 61,215 (2022) (“Irradiant Order”).  Nonetheless, it serves as an important reminder to those who own QFs, or are considering acquiring QFs, of the importance of keeping a QF’s Form No. 556 up to date, and the potential adverse consequences of failing to do so.

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