A Few Thoughts On FERC's Civil Penalty Calculations
February 28, 2013, 4:17 PM EST
Law360, New York (February 28, 2013, 4:17 PM EST) -- The Federal Energy Regulatory Commission has issued policy statements that describe the guidelines it follows to calculate civil penalties for violations of FERC regulations. Parties that are subject to an investigation by FERC’s Office of Enforcement should prepare a spreadsheet that will assist them in calculating the amount they may be required to pay in the event that they are not able to obtain closure of the investigation without any liability.
The subject of the investigation can use the spreadsheet to evaluate various scenarios based on...