Audits and Enforcement
As the Federal Energy Regulatory Commission (“FERC”) has intensified its focus on both standard accounting audits and enforcement audits, the representation of clients in the audit arena has become an increasingly important part of CBL’s practice on behalf of our clients. Our attorneys are intimately familiar with FERC’s accounting system, FERC ratemaking and FERC’s audit process and protocols. Several of our lawyers have audit and enforcement experience. Susan Beall Kittey worked for three years in enforcement at FERC (ending in 2015), handling complicated investigations, self-reports, and hotline matters. She was also the team lead for the annual report of enforcement which highlights enforcement and audit activities. She was a member of the trial team seeking the enforcement of the Commission’s Order Assessing Civil Penalties in one of the first Commission market manipulation cases under the Energy Policy Act of 2005.