FERC ALJ.
FERC Administrative Law Judges (FERC). No published AI policy as of May 2026.
FERC ALJ AI policy status. #
FERC's Office of Administrative Litigation (OAL) and its administrative law judges hear proceedings on electric and natural-gas rate matters, interstate pipeline certifications under the Natural Gas Act §7, hydropower licensing under the Federal Power Act, and related regulatory adjudications. Representative practice is governed by 18 CFR Part 385. As of May 2026, no published AI policy applies to representative AI use in FERC ALJ proceedings.
Authoritative source: https://www.ferc.gov/about/offices/oalj
Last verified: . If this row text disagrees with the linked source, the source controls.
Why FERC ALJ matters. #
FERC practice is among the most technically demanding in federal administrative law — the docket involves engineering exhibits, economic / rate-design models, environmental impact analyses, and substantial expert testimony. AI use by counsel is growing rapidly, particularly for summarization of multi-thousand-page engineering exhibits and analysis of utility cost-of-service models. The body of FERC law is small-but-distinct, with five interlocking sources: the Federal Power Act (16 USC), the Natural Gas Act (15 USC), the Interstate Commerce Act provisions for oil pipelines (49 USC App.), 18 CFR (FERC regulations), and FERC Stats. & Regs. orders. AI tools regularly confuse these sources — citing FPA cases as NGA precedent, or misattributing rate-design rationale between Order 888 (electric) and Order 636 (natural gas).
Practice implications. #
FERC ALJ representatives should: (1) follow ABA Op. 512 + applicable state-bar guidance; (2) be especially careful with AI-generated FERC precedent — the five-source citation structure is a known AI-confusion pattern, and the dollar stakes of FERC rate-design cases (often in the hundreds of millions) make verification non-negotiable; (3) verify AI-generated technical content against underlying source data — engineering models, rate computations, and environmental analyses are not just legal claims but technical claims that require verification at both layers; (4) the FERC Office of Administrative Litigation has internal AI use, but no public policy on representative conduct as of May 2026. Watch for the FERC Office of Enforcement to issue guidance first, since that office has been the most AI-active in informal settings.