FERC Issues Report Discussing Office of Enforcement Audit of Rockies Express Pipeline LLC

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The Federal Energy Regulatory Commission issued an Audit Report on November 29, 2012 summarizing the audit of Rockies Express Pipeline LLC performed by the Office of Enforcement’s Division of Audits (Docket No. PA11-5-000). The Audit Report provides useful insights into the conduct of a FERC audit of an interstate natural gas pipeline company, the detailed information that Audit Staff will examine and the Office of Enforcement’s expectations regarding strict compliance with FERC’s accounting, posting, and tariff implementation requirements.

Audit Staff identified a number of areas in which Rockies Express had failed to comply with FERC requirements or provisions of the pipeline’s tariff. The report describes a total of fifteen recommendations to remedy these areas of noncompliance. Rockies Express has agreed to implement all of the Staff recommendations. In addition, Rockies Express has agreed with Staff recommendations that it (i) submit plans for implementing the Staff’s recommendations, (ii) prepare nonpublic quarterly submissions describing its progress in implementing Staff’s recommendations, and (iii) submit nonpublic copies of all written policies and procedures developed in response to Staff’s recommendations. The audit report does not discuss imposition of any other penalties or sanctions against Rockies Express.

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