On July 13, Footprint Power LLC and Footprint Power Salem Harbor Operations LLC (Footprint) filed a Notice of De Novo Election in FERC Docket No. IN18-7 exercising their rights under § 31(d)(1) of the Federal Power Act to the federal district court path described in § 31(d)(3) of the Federal Power Act. Footprint asserts that any FERC action would be time barred by the statute of limitations set forth in 28 U.S.C. § 2462. If FERC nonetheless decides to assess penalties, however, Footprint invokes its statutory right to review of that penalty in federal district court, where the court “shall have authority to review de novo the law and the facts involved, and shall have jurisdiction to enter a judgment.”