This case exposes a clash between regulatory rigor and market innovation in energy policy. At its core, the dispute hinges on whether American Efficient’s business model—aggregating energy savings from retail sales data—constitutes legitimate efficiency or manipulative financial engineering. FERC’s allegations rest on the claim that the company’s micropayments to retailers (e.g., 5 cents per appliance) lack causal proof of reducing energy demand, while American Efficient insists its model aligns...