Experience
Lead counsel advising and representing an RTO in all aspects of design, development, regulatory approvals, implementation, ongoing review, and further refinement of “Day 2” day-ahead and real-time energy, reserves, and congestion rights markets.
Lead counsel representing a public utility client in a regulatory audit of its operations and accounting.
Counseling and representing a group of RTO members through a successful prosecution before FERC, federal appellate courts and the U.S. Supreme Court of a major redesign of regional transmission cost allocation.
Advising and representing various RTO and RTO member clients on developing and implementing compliance with a major FERC rulemaking related to regional and interregional transmission planning and cost allocation, including representation in various appeals of the FERC rulemaking and subsequent FERC orders on compliance.
Representing a group of public utility RTO members in a successful effort to secure incentive return on equity adders for RTO participation.
Advising and representing an RTO in proceedings to reform regional transmission planning processes and cost allocation methodologies.
Successfully defending an RTO against complaints challenging its regional cost allocation methods.
Counseling and successfully prosecuting before FERC several public utility applications for FERC approval of transmission rate incentives and forward-looking transmission formula rates.
Counseling and representing RTO and RTO-member clients on compliance with various FERC rulemakings related to energy market reforms, market monitoring, demand response accommodation and compensation, credit policy reforms, frequency regulation compensation and transmission planning and open access.
Defending a group of public utility clients in litigated proceedings challenging their transmission rates.
Advising a client on exemption from Commodity Futures Trading Commission regulation under the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Representing an RTO and other public utilities in obtaining energy export authorizations from the Department of Energy.
Defending an RTO against numerous complaints challenging its revenue crediting processes and implementation.