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Standards Of Conduct Go INGAA’s Way
INGAA also won on a second issue, FERC’s reference in the proposed rule to a “per se” approach – as opposed to a “rule of reason” approach – toward determining violations. INGAA objected to the use of the term “per se,” feeling it would allow the commission too wide a berth on enforcement actions. In the final rule, FERC soothed INGAA’s concerns saying it did not mean to establish a new standard of review or impose different evidentiary burdens specific to these rules.