Actively counseling clients on matters involving the application of FERC's new Enforcement Policy Statement and expanded civil and criminal penalty authority under the EPAct 2005, the development of comprehensive internal FERC compliance programs, and related corporate governance implications.  Represents and defends clients subject to operational audits or investigations by FERC's Office of Enforcement.

Provides day-to-day counsel to multiple clients regarding FERC's new Market Manipulation, Reliability and False Statements rules, Standards of Conduct, Code of Conduct, Market Behavior Rules, Price Reporting Policy Statement, Open Access Transmission and OASIS requirements.  Provides advice and counsel on risk management matters involving the physical and financial trading of energy and energy-linked commodities, as well as related credit support and fuel procurement issues.

Relevant Experience Energy Regulatory — Enforcement and Compliance Representations

• Represents electric utility clients in the development of corporate governance programs designed to adequately identify, prioritize and support compliance with applicable FERC regulatory obligations.
• Represents Midwest public utility in operational audit for compliance with FERC's Standards of Conduct, Code of Conduct, Market Behavior Rules, and Open Access Transmission Tariff and OASIS requirements, brought by FERC's Office of Market Oversight and Investigation (now the Office of Enforcement).
• Represents public utility holding company on FERC compliance and enforcement matters relating to restructuring of midstream gas operations.
• Represents multi-system public utility holding company with operations in the Midwest and Mid-Atlantic regions on day-to-day FERC compliance and enforcement matters.
• Represents Texas electric utility with operations on day-to-day FERC compliance and enforcement matters, including reliability rules.
• Represented Midwest public utility on the development and implementation of a comprehensive, internal FERC compliance program.
• Represented generating subsidiary of multinational power developer on strategic and day-to-day matters relating to the development of internal compliance program designed to address FERC's Code of Conduct, Market Behavior Rules, Price Report and Market Manipulation rules.
• Represented corporate parent of a multinational power developer on strategic matters involving the structuring of centralized energy trading operations and appropriate risk management oversight functions in compliance with the FERC's Standards of Conduct and Code of Conduct requirements.
• Represented Midwestern public utility on the development of FERC Order No. 889 Standards of Conduct compliance program.

Energy Regulatory — Non-Enforcement Representations

• Represents Australian independent power developer on state and FERC regulatory matters relating to the development of business strategies designed to maximize value of renewable energy credits generated by PURPA small power production operating subsidiaries.
• Represents affiliated energy marketer relating to the implementation of Midwest ISO Day 2 energy market rules for revenue sufficiency guarantee charges.
• Represents affiliated energy marketer in Midwest ISO/PJM SECA/Shift-to-Shipper proceedings.
• Represented energy marketer in FERC complaint proceedings addressing the proper application of Midwest ISO open access transmission tariff.
• Represents clients participating in competitive energy markets on regulatory issues including market design, preparation and filing of market-based rate applications, and interconnection arrangements.
• Represented public utility and transmission-only clients on Midwest RTO development and implementation issues, including inter-RTO transmission pricing, lost revenue recovery and distribution, and seams issues.
• Represented stand-alone transmission company in obtaining initial FERC approval of an ITC operating construct under Appendix I of the Midwest ISO Agreement.
• Represented Midwestern generation and distribution company in cost-based rate proceedings involving the filing of an ancillary services tariff.

• Obtained expedited FERC regulatory approval for multinational power developer in $260 million divestiture of national wholesale and retail energy marketing subsidiary to a large public utility holding company.
• Represented public utility holding company on strategic, regulatory and transactional issues regarding the formation and divestiture of first independent transmission company operating in the Midwest ISO, including drafting and negotiation of multiple operating agreements between ITC and former public utility affiliate.
• Represented large affiliated power developer on FERC regulatory and transactional issues involving the acquisition of approximately 11,000 MW of generating assets in the California, New England and the Mid-Atlantic region.
• Obtained required FERC regulatory approvals for clients involved in merger and acquisition transactions in the electric industry with an aggregate value in excess of $7 billion.
• Obtained FERC approvals required for the spin-out vertically integrated generating business by public utility holding company to a genco subsidiary and FERC approval of market-based affiliate power sales arrangement.
• Obtained FERC approvals required for the divestiture of a large Midwest nuclear power facility.
• Represented affiliated power developer on FERC regulatory and transactional issues involving formation of energy marketing joint venture with oil and gas producer/marketer.

Energy Trading and Risk Management-Related Representations

• Represents public utility, independent power producer and energy marketer clients on strategic business and regulatory matters involving the trading and marketing of energy and energy-linked commodities.
• Represents clients in connection with drafting and negotiating of master agreements for the physical and financial marketing and trading of energy and energy-linked commodities and related credit support documentation, including ISDA, EEI and NAESB Master Agreements.
• Represents generating subsidiaries of multinational power developer on the drafting and negotiation of fuel supply, fuel management, and management service agreements.

• Partner, Troutman Sanders LLP, January 2003-April 2005
• Associate, Troutman Sanders LLP, July 1997-December 2002
• Associate, Duncan, Weinberg, Genzer & Pembroke, P.C., April 1996-July 1997)
• Senior Research Fellow, Institute for Scrap Recycling Industries, Inc., January 1995-April 1996
• Associate, Devorsetz, Stinziano, Gilberti, Heintz & Smith, P.C., April 1993-May 1994

• Member, District of Columbia, New York Bar, and Massachusetts Bars
• Member, Energy Bar Association, American Bar Association, New York State Bar Association, Massachusetts Bar Association
• Associate Member, International Energy Credit Association
• Member; Lawyers Committee, Washington Performing Arts Society

• LL.M., The George Washington University, Executive LL.M Editor, The Environmental Lawyer, 1996
  
• J.D., Capital University Law Center, Member, Capital University Law Review, 1992
  
• B.A., St. Lawrence University, 1988