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The Federal Energy Regulatory Commission (FERC) approved the North American Electric Reliability Corporation's (NERC) new "Find, Fix, Track and Report" (FFT) procedures under which NERC may process minor violations of its Reliability Standards expeditiously and without monetary penalty. Surely that is welcome news to owners and operators of electric transmission and generation facilities that are otherwise subject to the NERC penalty regime. But ambiguities in the FFT procedures and FERC's approval order mean regulated entities must remain vigilant in their internal reliability compliance programs.
Sutherland Energy and Environmental Practice Group attorneys Daniel E. Frank and Jennifer J. Kubicek discuss the implications of NERC's FFT process and FERC's approval order in "Staying on Track with Reliability Compliance," published March 26, 2012 by Energy Law360.