On behalf of Idaho Power Company, Van Ness Feldman restructured and prepared a request for declaratory order to terminate a settlement between Idaho Power and FERC's Office of Enforcement stemming from actions by a formerly affiliated entity between 2001 and 2003 based upon the strength of Idaho Power’s compliance program. FERC’s settlement with Idaho Power is a seminal case defining the prohibitions on use of secondary network transmission rights to facilitate off-system electric power sales. In April 2012, FERC granted the request for declaratory order finding that the settlement’s protections “are no longer necessary in light of Idaho Power’s comprehensive compliance plan.” We have been central in the development and implementation of the compliance program.