Energy Regulation

Eric's energy regulatory experience includes:

  • Drafting and filing extensive comments on Federal Energy Regulatory Commission proposed rulemaking concerning key "Bulk Electric System" definition on behalf of a coalition of public power entities representing more than 200 individual utilities across the Western Interconnection.
  • Representing a Pacific Northwest utility in administrative proceedings before the Federal Energy Regulatory Commission and the Western Electricity Coordinating Council concerning the definition of "Bulk Electric System," a critical issue for defining the scope of federal electric reliability regulation.
  • Filing extensive comments on behalf of a Western utility in response to Federal Energy Regulatory Commission request for comments and a notice of proposed rulemaking concerning measures considered by FERC to improve integration of renewable generation, principally wind and solar power, into an interconnected electric grid.
  • Successfully representing a public power utility in opposing regional transmission organization in the Pacific Northwest, including opposition at the federal level, litigation (including the successful appeal of FERC Order No. 2000), participation in West-wide and regional processes aimed at creating a regional transmission organization.
  • Helping craft a compromise that allowed the formation of regional transmission planning body to capture many of the benefits of the RTO at substantially lower costs.
  • Representing Bonneville's largest customer in critical Bonneville administrative proceedings, including "Subscription" process (plan for allocating BPA capacity following expiration of all BPA contracts in 2001), "Regional Dialogue" (long-term plan for allocation of BPA resources, resulting in "Tiered Rate Methodology"), "Residential Exchange" (administrative and court proceedings challenging large payments to regional investor-owned utilities by BPA), and power and transmission rate cases.