FERC Filings
SYMPOSIUM ON PROCESS AND REFORM: COMMISSION COMPLAINT PROCEDURES
ENFORCEMENT OF TARIFF AND/OR POLICY VIOLATIONS MUST BE SWIFT AND MEANINGFUL.
For competitive markets to flourish, there must be meaningful respect for FERC policy and rules. To encourage such respect, FERC’s enforcement of violations must have sufficient "teeth." Merely requiring a transmission provider to do what it was already required to do, time after time, is inadequate. FERC should adopt a series of escalating penalties that would serve to discourage inappropriate commercial conduct, while adequately compensating aggrieved parties.
In addition, parties found to have violated FERC’s policies should be subjected to heightened scrutiny and enhanced reporting requirements. EPSA believes that for markets to flourish in a semi-regulated environment, dispute resolution and enforcement must be viewed as two sides of the same coin, neither of which can function without the other.