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Bracewell lawyers have analyzed and addressed issues involving NERC Reliability Standards since the standards became mandatory and enforceable. We have guided clients registered in multiple Functional Entity categories on a wide array of compliance issues. For example, in a proceeding watched closely by the industry, we represented a power marketer that was registered as a Load Serving Entity ("LSE"). On behalf of a Purchasing Selling Entity, we lodged a registration challenge to the LSE designation, which we successfully appealed before the Federal Energy Regulatory Commission. As a result of our success in this proceeding, most power marketers are not currently registered to comply with the LSE standards. Our lawyers have developed and drafted procedures to comply with the standards; we have also guided clients through the Self-Certification and Self-Report and Mitigation Plan process. As audits of our clients have been scheduled, our attorneys have advised clients how to navigate the data compilation and data response preparation process for the Pre-Audit Questionnaire and Reliability Standard Audit Worksheet, and through the post-audit follow-up review. We have worked with clients in negotiating settlements of Notices of Violation with Regional Entities and in implementation after approval by the Federal Energy Regulatory Commission. Our work handling a broad array of complex NERC issues constitutes a substantial component of our regulatory compliance practice.

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