On August 10, BP filed a request for rehearing of FERC’s order affirming the initial decision in the natural gas market manipulation case against BP. BP argues that the FERC order (Opinion No. 549) is not the product of reasoned decision-making and is not supported by substantial evidence. BP challenges FERC’s ruling that FERC need not establish that any of the allegedly manipulative trades had any hallmark of manipulation because they all were related to a presumed scheme. On the issue of jurisdiction, BP argues that Opinion No. 549 comprehensively fails to identify any allegedly manipulative transaction that falls within FERC’s jurisdiction under the Natural Gas Act. Finally, BP argues that Opinion No. 549’s application of the Penalty Guidelines is also arbitrary, capricious, and contrary to law.