On March 17, 2011, the Federal Energy Regulatory Commission ("FERC" or the "Commission") issued an order (the "March 17 Order") on review of a Notice of Penalty ("NOP") in which it affirmed the North American Electric Reliability Corporation's ("NERC's") proposed $80,000 penalty against Turlock Irrigation District ("Turlock"). The Turlock NOP, submitted by NERC on November 13, 2009, was the first that the Commission chose to review.