David is a member of the Federal Regulation of Electricity and Gas Practice Group. He has more than 26 years of experience in all types of matters related to FERC’s regulation of the electric utility industry. His areas of expertise include transmission rates and incentives; RTO markets, including capacity markets, and implementation of FERC open-access policies.
Representative Experience
Handled electric utility rate cases before the FERC and several state utility commissions.
Counsel utilities on compliance with Order Nos. 888 and 890.
Represented utilities in customer complaints regarding priority of transmission service under pre-OATT transmission agreement and prudency of O&M expenses.
Provide advice and counsel in development of tariff amendments implementing resource adequacy provisions, self-supply of station power, and the settlement process for an independent system operator.
Prepared request for transmission rate incentives pursuant to Section 219 of the Federal Power Act.
Represented utility in rate case regarding rate of return on equity, prudence of decision-making, and decommissioning funding.
Participated in proceedings involving developing the transmission access charge for two independent system operators.
Assisted in development of a standard capacity product for an independent system operator.
Participated in proceedings involving transfer of operational control of facilities by public and private entities to an independent system operator, and FERC rate cases associated with the transfer of facilities.
Engaged in cost benefit and legal analysis regarding RTO membership.
Represented California Independent System Operator Corporation in numerous FERC matters.
Participated in several proceedings regarding the prudence of the construction and operation of nuclear plants.
Worked on issues associated with the 1990 Clean Air Act Amendments, including assisting in the preparation of a delisting petition for a hazardous air pollutant, and prepared comments for NIOSH concerning an occupational air contaminant standard.
Presentations and Speaking Engagements
Panelist, "Discussion of FERC's Order No. 1000: Reforming Transmission Planning & Cost Allocation Requirements" webinar, August 2, 2011.