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Preparing for the Inevitable

Mitigating enforcement penalties in NERC hearings and appeals.

Fortnightly Magazine - March 2010

(Jan. 15, 2008) (last visited Jan. 15, 2010).

34. See Compliance with Statutes, Regulations, and Orders , 125 FERC ¶ 61,058, at P 12 (2008) (Policy Statement on Compliance).

35. See, e.g. , 18 C.F.R. § 39.7(e)(2) (2009) (allowing submission of evidence during appeals process).

36. FPA § 215(e)(6); 18 C.F.R. § 39.7(g) (2009).

37. Enforcement of Statutes, Regulations and Orders , 123 FERC ¶ 61,156, at P 54 (2008) (Revised Policy Statement on Enforcement).

38. See North American Electric Reliability Corp ., 129 FERC ¶ 61,119, at P 41 (2009).

39. Supra, note 34.

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