NERC filed a Request for Rehearing yesterday, listing a bunch of alleged "errors" committed by FERC audit & enforcement staff during and after the audit, and requesting that the Commission conduct a paper hearing and issue a decision to cut their own staff off at the knees and turn them into a paper tiger.
NERC also filed a "Statement on Procedures" as a supposed better alternative for the Commission to resolve this matter. NERC proposes "a paper hearing process that would allow all interested parties to express their views on all 42 recommendations contained in the Final Audit Report and allow the Commission to resolve them on a comprehensive basis." So, NERC wants some FERC free-for-all where they imagine their fans will come rushing to their defense and attack FERC staff. NERC imagines that, "load serving entities (and the trade organizations representing them) that are directly impacted by NERC’s budget, programs and financial controls," will come rushing to their defense in order to brown nose shamelessly, because NERC will in turn audit these entities in the future. Well, now, isn't that a great idea? As if the audit didn't uncover enough problems, now NERC is soliciting favors from the entities it "regulates."
Unfortunately for NERC, "interested parties" aren't limited to just "load serving entities," because load serving entities merely pass along NERC's costs to end users (you, the consumer). This also makes consumers "interested parties" encouraged to comment under NERC's proposed "procedures." FERC has previously found that "consumers that are not direct wholesale customers may have a sufficient direct interest in proceedings that affects their retail rates..."
You could file your own comments. Since NERC has attempted to turn FERC into a circus, you could prepare a proper letter and let NERC know that you're tired of paying for their holiday galas, social events and other non-statutory programs.
Some good points to make: how much NERC's high-priced outside counsel are going to cost YOU, the ratepayer, in addition to FERC's time and expense to entertain this ridiculous proposition. Use your best courtroom manners, please ;-)
NERC just doesn't get it. Their pure, shameless arrogance is wasting everyone's time and money. If FERC's audit & enforcement staff is supposed to blindly accept NERC's re-write of their audit findings, what was the point of the audit in the first place? Is that the way NERC conducts audits of those entities under its jurisdiction? If so, run, don't walk, to your nearest solar dealer and arrange for them to install your own power generation system today because the lights may go off at any second. I wonder if what FERC has given (designation as the ERO), FERC can also take away? Or perhaps NERC will flounce out the door if they get their fee-fees further injured by interested parties' comments?
For Thomas Edison's sake, NERC, grow up, you're acting like a bleating 2-year old!
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