Rebecca counsels clients regarding matters at the Federal Energy Regulatory Commission, with a particular emphasis on electric tariff and rate matters for investor-owned utilities. Rebecca handles regulatory compliance matters on a day to day basis and has represented clients in administrative litigation proceedings involving rate, tariff, and transmission pricing issues.
Representative Experience
Provide advice and counsel to investor-owned utility on generator interconnection queue reform.
Provide advice and counsel to several utilities related to compliance with Order No. 890, the open access rulemaking by the Federal Energy Regulatory Commission.
Provide advice on compliance with North American Electric Reliability Corporation (“NERC”) Standards.
Provide advice and counsel to investor-owned utilities on generator and transmission interconnections.
Represented several utilities in Federal Energy Regulatory Commission proceedings relating to cost of service and rate design for ancillary services. Proceedings included settlement procedures, litigation, discovery and brief writing.
Represented large investor-owned utility before the Federal Energy Regulatory Commission regarding transmission formula rates.
Represented large Midwestern utility and energy trading company in Federal Energy Regulatory Commission proceedings relating to transmission pricing and transmission rate design. Proceedings include litigation and settlement procedures on inter-RTO transmission rates, lost revenues and proposals to establish a Seams Elimination Charge/Cost Adjustment/Assignment ("SECA") rate mechanism and "hold harmless" requirements.
Represented and counseled utilities in ongoing litigation before FERC and the U.S. Courts of Appeals involving the “Western Energy Crisis” of 2000-2001.
Represented Midwestern utilities regarding existing transmission contracts and obtaining grandfathered agreement status in the Midwest ISO/MISO service territory. Representation included integration of pumped storage hydroelectric unit into new market regime.
Represented utility companies in evaluating jurisdiction over rail construction projects, obtaining authority from the Surface Transportation Board (STB) when needed to construct and operate rail lines, and/or acquiring certain rail lines or obtaining trackage rights. Assisted in securing environmental permits as required from the STB, U.S. Army Corps of Engineers and other regulatory agencies.
Publications
“States Refuse to Roll Over on Transmission Siting: Corridors Continue to Meet Opposition,” Troutman Transmission Monthly, January 14, 2008.
Co-author, “Energy - Reliability Standards Ready to Take Effect: FERC Ready To Enforce,” Troutman Transmission Monthly, May 30, 2007.
Presentations and Speaking Engagements
Panelist, "Discussion of FERC's Order No. 1000: Reforming Transmission Planning & Cost Allocation Requirements" webinar, August 2, 2011.