Cases
Experience: Government Investigations
Compliance: Represented an energy trading company
individual traders regarding FERC manipulation investigation of relational trading, physical power schedules
congestion revenue rights in Western markets, resulting in no enforcement action.
Represented a trading company
individuals regarding FERC manipulation investigation of schedules
inaccurate information claims in the CAISO market, resulting in no enforcement action.
Represented a financial institution
individuals regarding FERC manipulation investigation of physical
futures trading in the Eastern interconnect, resulting in no enforcement action.
Represented trading company
, separately, dem
response provider, in several self-reports regarding trading strategies or asset capacity market registration, each resulting in no enforcement action.
Represented generation owner regarding generation capacity
trading strategy analysis of market power in ERCOT.
Provide several clients with 'root cause' analyses
internal audit services. Established compliance regimes
evaluation metrics for scores of energy companies, including on-going energy trading
scheduling advisory services.
Revised natural gas marketer's sales
energy asset management operations to ensure FERC compliance, including with Order 712.
Advise energy marketer regarding Texas anti-fraud
anti-manipulation rules.
Assisted multiple clients with initial inquiries from market monitors,
various FERC divisions
offices regarding natural gas
electricity matters throughout the U.S.
Assisted a dem
response provider regarding enforcement
compliance matters.
Assisted wind generator regarding NERC enforcement matter.
Defended energy marketers regarding various FERC enforcement theories involving day-ahead
real-time energy, up-to congestion, virtual,
FTR equivalents transactions, including physical
financial,
fundamental
quantitative trading.
Represented an asset manager/generator regarding CFTC review of generator obligations in ERCOT, resulting in no enforcement action.
Represented financial institution
asset/manager/generator regarding FERC investigation of capacity supply obligation in ISO-NE, resulting in no enforcement action.
Represented an energy trading company
individual traders regarding FERC's manipulation investigation of relational
loss leader trading involving financial products, physical transactions
virtual trading in the eastern interconnect markets including NYISO, ISO-NE, PJM, MISO
Ontario, resulting in a settlement.
Represented a trading company regarding FERC enforcement's investigation of Lake Erie electricity loop flow causation
impact, resulting in no enforcement action.
Represented energy trading companies
individual traders regarding FERC investigation of manipulation
tariff violation allegations in the western markets
, separately, in the eastern markets, resulting in closed matters
a settlement.
Represented primary ISO market systems software developer accused of aiding manipulative conduct before California
U.S. legislative committees, the FERC
California PUC,
California attorney general, resulting in no enforcement action.
Advised on
conducted compliance audit regarding regulated utility
marketing affiliate FERC st
ards of conduct (e.g. including cross subsidy, functional separation, transmission
interconnection issues)
NERC rule implementation.
Advise energy companies regarding Dodd-Frank Act (DFA) compliance.
Federal
State Regulatory Matters: Advised energy company regarding capacity supply obligations in ISO-NE.
Advise energy marketers regarding market design
policy issues involving day-ahead
real-time energy, up-to congestion, virtual,
FTR equivalents transactions, including fundamental
quantitative trading.
Advised multiple trading companies regarding PJM, ISO-NE, CAISO, MISO, IESO
NYISO
retail market design
rules.
Advised wind
geothermal developers regarding interconnection
transmission requirements in MISO, NYISO
other regions.
Reviewed multiple state 'public utility' status rules for rooftop solar developers.
Advised traders
developers regarding state RPS
REC documentation, trading,
tracking rules throughout the United States.
Advise energy storage
dem
response providers regarding energy
capacity market participation in ISO-NE
PJM, including auction strategies
capacity supply obligation management.
Assist retail marketer regarding state utility commission compliance obligations
reporting rules
Advise energy companies regarding DFA swap dealer analysis, on-going business structure, compliance
timelines.
Advise energy companies regarding numerous energy contract DFA issues including swaps
options definitions, embedded optionality, trade options
advisor issues.
Advised generation developer regarding New Jersey
Maryl
'contract for difference' long-term capacity rules, agreements
court challenges.
Represented a utility
its marketing affiliate in FERC pipeline wholesale rate
tariff proceeding resulting in successful settlement.
Represented large department store chain as an energy consumer in retail rate, dem
response
energy efficiency proceedings before 10 state utility commissions.
Submitted time-sensitive requests for FERC authorization
related waivers to transfer energy assets including contracts
capacity rights on behalf of various banks
funds under the FPA
NGA.
Represented financial institution before FERC regarding ancillary services markets
procurement resulting in a successful settlement.
Represented regulated utility in merger proceeding before the FERC.
Develop regulatory strategy for cross-border Canadian LNG project.
Counseled clients regarding matters before more than 20 state utility commissions.
Transactional
Project Development Matters: Energy regulatory counsel for Puerto Rico Electric Power Authority as it entered financial
regulatory restructuring including advice on PPAs, integrated resource planning, rate setting, microgrids, DERs
regulatory policy as it interrelates with restructuring efforts.
Lead energy regulatory counsel for dem
response provider acquisition of another entity.
Lead energy regulatory counsel for financial client purchasing large solar project in terms of FERC FPA 203
205 matters
QF, EWG, PUHCA
PURPA analyses.
Lead energy regulatory counsel for an energy trading fund entering into a financial swap
bridge lending related to a developing generation project to meet interconnection milestones.
Lead energy attorney for development group regarding FPA, PURPA
PUCHA legal opinions related to financing
development of several large wind
solar generation projects throughout the United States.
Represented energy trading company in the potential acquisition of the book of trades
transactions of another trading entity.
Develop trading, financing
wholesale power supply documentation
regulatory licensing for two retail marketers.
Lead regulatory counsel preparing an energy asset company for sale including advice regarding diligence, documentation
regulatory requirements.
Regulatory counsel advising Mercuria Energy Group Limited's $3.5 billion acquisition of a bank's global commodity business.
Lead regulatory counsel on acquisition of natural gas trading business.
Represented renewable power developer regarding regulatory issues in sale of 100 MW biomass facilities located in Texas.
Represented a bank subsidiary regarding regulatory matters in its formation of a strategic alliance with a national solar project developer.
Represented banks regarding st
ard offer/default/basic generation service procurements (e.g., auctions), supply contracts
credit support in 11 states.
Represented a wind developer regarding regulatory issues associated with a secured financial hedge as part of the financing of wind facilities.
Negotiated multiple PPAs
REC agreements for multiple facilities
buyers utilizing various master
homegrown formats
credit support methods.
Conducted large scale due diligence
advised investor/developer regarding interconnection
transmission rights, including issues of site control
queue position, regarding wind projects in the west/midwest.
Developed municipal cooperative generation project structures
documentation.
Negotiated generation operation
maintenance, lease,
development agreements for power plant projects.
Analyzed the restructuring
acquisition of debt
equity in 10 distressed generation companies throughout the United States.
Represented large department store chain as an energy consumer regarding solar
wind PPA
REC agreements.
The above matters were h
led by Mr. Lawrence prior to his joining Greenberg Traurig, LLP.
In-House Experience: Counsel, Massachusetts Department of Public Utilities, 1991-1993
