Enforcement
Recent FERC Enforcement Efforts Reported
FERC’s Office of Enforcement on November 6 released its “2008 Report on Enforcement,” an annual report detailing FERC’s enforcement program during the preceding fiscal year ending September 30. This report provides a statistical analysis of FERC’s enforcement activities, including receipts of company self-reports and investigations opened by FERC staff. In a statement issued concurrently with [...]
First NERC Penalty Notices Suggest Focus on Enforcement
On June 4, 2008, the North American Electric Reliability Corporation made its first public announcement of its Notices of Penalty when it filed at FERC the first batch of proposed penalties for reliability standard violations. Most Notices of Penalty filed with FERC were for a zero penalty amount, however, Baltimore Gas & Electric and MidAmerican [...]
FERC Augments, Revamps Enforcement Guidance and Procedures
FERC has taken several steps to clarify its policies for conducting enforcement investigations, carrying out its authority to impose penalties on violators, and broadening the scope of issues to be covered by its ex parte rules and no-action letter procedures. The additional guidance is welcome in light of the seemingly haphazard approach to enforcement that [...]