This white paper, written by Pamela Dautel and Kimberly Richardson of ICF International, summarizes the events surrounding the Federal Energy Regulatory Commission (FERC) decision that required New Harquahala Generating Company to register as a transmission owner and transmission operator in the Western Electricity Coordinating Council (WECC) Region. The paper also includes an analysis of the Harquahala case and what it may mean to other registered entities.