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Experience
Utility Regulatory Proceedings
Represent local distribution companies (LDCs), electric utilities, pipelines and large energy users in rate cases, certificate proceedings and prudence reviews at FERC and before state utility commissions.
Utility Tariffs
Review and assist gas and electric utilities and oil and gas pipelines in preparing proposed tariff changes and defend against protested tariff change filings.
Regulatory Compliance
Conduct comprehensive compliance reviews, develop compliance programs and procedures, and prepare and perform compliance training concerning FERC and state utility regulations.
Compliance Counseling
Counsel clients regarding energy compliance issues, including CFTC Dodd-Frank requirements, FERC’s rules concerning standards of conduct (SOC), market manipulation, code of conduct, price reporting and open access transmission requirements. Also assist in establishing appropriate internal controls, procedures and trainings.
FERC Enforcement
Represent clients in all aspects of non-public FERC enforcement proceedings, including calls to the FERC Hotline, responding to calls to the FERC Hotline, preparing “no-action” letter requests, performing internal investigations, which may lead to self-reports, and responding to staff investigations.
Accounting Compliance
Counsel gas and electric utilities, and gas and oil pipelines regarding internal accounting rules, the Uniform System of Accounts, and reporting and records retention requirements.
Pipeline Open Seasons
Counsel pipelines and shippers in preparing open season materials and during the open season process. Also assist with drafting and negotiating precedent agreements.
Renewable Energy
Counsel utilities and project developers on the sale or purchase of renewable energy projects, renewable natural gas, renewable energy credits and other types of environmental attributes, including due diligence and federal and state regulatory compliance.
Interconnection Negotiations
Counsel utilities and utility customers regarding FERC generator interconnection rules. Also assist in drafting and negotiating system impact study agreements, facilities study agreements and interconnection agreements.
Power Purchases
Represent electric companies and project developers in negotiations of power purchase agreements, including due diligence and regulatory compliance.
Electric Reliability
Represent owners or operators of the bulk-power system in their efforts to comply with reliability standards enforced by the North American Electric Reliability Corporation (NERC) and regional reliability entities.
Interstate Commerce Act Counseling
Counsel oil pipelines and shippers in all aspects of FERC regulation and common carrier obligations under the Interstate Commerce Act.
FERC Proceedings for Oil Pipelines
Successfully represent oil pipelines in protested index-rate proceedings, and litigated cost-of-service and market-based rate proceedings. Represent shippers and pipelines in complaint proceedings, including settlement judge proceedings and using the FERC alternative dispute resolution service.
Representative Matters
- Secured state regulatory approval for an LNG storage facility to serve utility peaking and maritime fuel needs.
- Represented an electric cooperative intervenor in various state rate case proceedings, including cases filed by a transmission pipeline, a distribution pipeline and a natural gas storage company.
- Successfully defended against a request for advance determination of prudency for redundant facilities.
- Secured state regulatory approval of pipeline tariff provisions governing acceptance of renewable natural gas.
- Represented an electric utility in converting a power purchase agreement to the joint purchase of a 130 MW wind farm.
- Represented a municipal utility in developing power purchase agreement templates for solar and solar + storage purchases.
- Counseled a natural gas utility in negotiating agreements for renewable natural gas injection and in purchasing and selling renewable natural gas and environmental attributes.
- Represented a local distribution company in rate case settlements with interstate natural gas pipelines.
- Advised a local distribution company in negotiating lateral facility expansion agreements with interstate natural gas pipeline.
- Secured approval of a Presidential Permit for natural gas import facilities.
- Advised a lighting manufacturer and distributor concerning compliance with DOE energy efficiency regulations.
- Advised a refiner in negotiating and drafting a settlement agreement with a pipeline concerning transportation and transmix recovery fees.
- Assisted an oil pipeline in filing rate change tariffs at the FERC and the Regulatory Commission of Alaska.
- Assisted an oil pipeline in bringing its FERC reporting issues current and achieved a successful outcome from a self-report of the issue to FERC Enforcement.
