Appeals and ERO Review of Penalties. 166. The ERO Certification Order required NERC to revise its Uniform Compliance Program, to: (i) clarify NERC’s intention to review penalties imposed by a Regional Entity (i.e., whether it intended to review each such penalty, or do so only in the case of an appeal); (ii) provide for an appeal of NERC determinations; (iii) consider the appropriateness of an expedited appeal process for remedial action directives; and (iv) permit requests for reconsideration of a mitigation plan when an entity is issued a real- time remedial action directive.100 100 ERO Certification Order, 116 FERC ¶ 61,062 at P 366, P 369 and P 492-93. Mitigation plans are addressed in the Uniform Compliance Program at section 6. See supra section IV(B)(3).
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