Jeffrey counsels clients regarding matters at the Federal Energy Regulatory Commission (“FERC”), particularly those focusing on electric company mergers and power sales. Holding a bachelor’s degree in quantitative economics, Jeffrey’s practice focuses on matters at the crossroads of law and economics, particularly in the workings of energy markets. Jeffrey has developed proprietary quantitative analytical tools that he uses to advise clients on electric asset transactions, market-based rate authorizations, and litigation risk.
Representative Experience
Represented and counseled electric utilities in FERC investigations into ongoing authorization to sell power at market-based rates, including litigation. Prepared FERC market-based rate authorization applications and triennial market power updates.
Represented and counseled companies and individuals in FERC Office of Enforcement investigations into electricity trading activities.
Represented and counseled electric utilities in FERC transmission rate cases involving both stated and formula rates, including litigation.
Represented and counseled electric utilities regarding FERC approval of large-scale generation asset sales and utility mergers, particularly, market power impacts thereof. Prepared and filed applications for FERC approval of such transactions. Developed quantitative “Delivered Price Test” analyses of market impact of potential transactions.
Represented and counseled electric utilities responding to audits and investigations concerning compliance with FERC’s Standards of Conduct, NERC’s Reliability Standards, and RTO market rules.
Represented and counseled electric utilities in the negotiation of large-scale power purchase agreements.
Represented one of the nation’s largest banks in the financing of a 55MW utility-scale solar facility (approximately $250MM in value) in New Mexico. The bank provided the construction financing and will provide the long-term financing.
Drafted "white papers" for electric utilities on economic and market impacts of federal regulatory policy decisions.
Represented and counseled electric utilities in ongoing litigation before FERC and the U.S. Courts of Appeals involving the "Western Energy Crisis" of 2000-2001, including development of quantitative models of potential liability and litigation risk.
Represented and counseled electric utilities in FERC proceedings concerning modification of market rules for the Midwest ISO, California ISO, and ISO New England.
Drafted electricity market rules for regional transmission organization.
Presentations and Speaking Engagements
"Let the Beneficiaries Pay (So Who Are They?)," (presented at the EUCI Conference Transmission Investment at Risk, October 19-20, 2006, Arlington, VA).
"Marginal Cost Pricing Has Little Place in Electricity Regulation," (presented at the 24th Annual North American Conference of the United States Association of Energy Economics, July 8-10, 2004, Washington, DC).
"Time-Of-Use Electricity Pricing Should Be Mandated As A Public Good," (presented at the 26th Annual International Association of Energy Economics conference, Prague, Czech Republic, June 4-7, 2003).
Publications
Co-author, "Effective Metering and Billing Strategies for DSM," (presented at Metering, Billing and CRM/CIS Europe 2003, Paris, France, October 2003).
"Maintaining Air Safety at Less Cost: A Plan for Replacing FAA Safety Regulations with Strict Liability," Cornell Journal of Law & Public Policy, Winter 1997.