Read with interest Staff’s proposal for adoption in docket 41659. Staff’s proposal makes clear that staff would not have to prove-up a violation in order to seek a cease and desist order. Given the example cited in the preamble discussion (a REP incorrectly using transactions during an extreme weather emergency) as a customer harm that could not be remedied monetarily, it is easy to construe that almost any other alleged wrongful disconnect could also rise to this level. Expect the Commissioners to approve this at the open meeting though. Clearly sets a tougher compliance tone.