Chris Zentz represents utilities, generation developers, independent power producers, and merchant transmission developers on a range of regulatory and transactional matters involving the energy industry. Chris has significant experience assisting clients with regulatory issues arising under federal energy statutes such as the Federal Power Act (FPA) and Public Utility Regulatory Policies Act, and frequently involving the Federal Energy Regulatory Commission (FERC). Chris also regularly represents clients in their interactions with the Bonneville Power Administration.
Chris’s federal regulatory experience encompasses Open Access Transmission Tariff (OATT) compliance; representation of utilities in administrative and court proceedings; counseling entities regarding ongoing compliance matters; participation in organized and unorganized markets, particularly including involvement and participation in the California Energy Imbalance Market (EIM); the transmission planning process; facility development, permitting, and operations at state and federal levels; FERC and multi-agency market manipulation proceedings; and FERC audits. This experience also extends to the representation of utilities and electric cooperatives on compliance and enforcement matters before the North American Electric Reliability Corporation (NERC) and the Western Electricity Coordinating Council (WECC), especially those involving compliance with NERC’s mandatory reliability standards.
Chris’s transactional experience includes assisting clients with obtaining FERC approvals related to the purchase and sale of electric assets, energy project financing arrangements, and sales from facilities at market-based rates, as well as providing transactional due diligence for project and parent companies in the energy and natural resources sector during acquisitions, mergers, or dissolutions.
- Represents one of the largest, independently-owned utilities on all matters of regulatory compliance before the FERC and various state utility commissions, including in administrative hearings and informal disputes with a federal power marketing agency, and on ongoing regulatory compliance issues.
- Provides regular advice and counsel to nationwide developer of renewable energy assets on issues such as FERC compliance, qualifying facility certification and reporting, and proactive identification of upcoming FERC reporting obligations.
- Served as attorney team lead assisting a client in acquiring a large, closed-loop pumped storage hydroelectric project, which representation included transactional due diligence, document negotiation and drafting, environmental review and permitting, land rights issues, and FERC licensing.
- Ongoing transactional and permitting advice for an international utility and project developer seeking to acquire and develop large, utility-scale energy storage and generation projects throughout the Western United States.
- Advising a large, independently-owned utility on preparation and filing of a rate case with FERC to update ancillary services rate schedules, which includes providing assistance and representation throughout the FERC hearing process.
- Representation of a Midwest utility with FERC compliance obligations, including eTariff filings and termination of legacy agreements.
- Represented a large, independently-owned utility in defending a complaint brought by the Bonneville Power Administration before FERC regarding interpretation of the OATT and legacy contracts, rollover rights upon termination of grandfathered transmission agreements, and load service under pre-Order No. 888 agreements.
- Advised large, independently-owned utility and renewable energy developer regarding FERC’s triennial market power reporting requirements, FERC’s market-based rate rules, and successful and timely completion of the triennial reporting process.
- Counseled a large, independently-owned utility through obtaining FERC approval for two acquisitions of combined cycle gas generation facilities from unaffiliated third parties.
- Represents several of the initial California Independent System Operator Corporation EIM Entities on all stages of start-up and compliance, including drafting regulatory filings and documents; providing advice regarding compliance obligations; preparing OATT revisions, business practice manuals, and other internal compliance manuals; and staying abreast of changes in market structures.
- Advised a large Northwest utility on OATT and business practice compliance issues, reliability standards, standards of conduct, market behavior rules, interlocking director rules, electronic quarterly reporting, and accounting rules.
- Represented a large, independently-owned Northwest utility in connection with a FERC audit and subsequent OATT compliance matters.
- Represented two large, institutional investors in renewable generation facilities in obtaining requisite FERC approvals and authorizations to acquire interests in over $2 billion worth of energy assets.
- Represented a coalition of large, independently-owned utilities throughout the FERC Order No. 1000 Regional and Interregional Transmission Planning and Cost Allocation compliance process.
- Represented a coalition of small, public-power utilities in seeking, for the first time, a local distribution jurisdictional exemption from the mandatory reliability standards at FERC.
- Represented one of the largest publicly-traded companies in various real estate transactions, including a record-breaking land acquisition of the company’s headquarters, complex lease negotiations, build-to-suit transactions, and acquisition of warehouse space.
- Counseled a developer of a manure digester system for the production of renewable natural gas on all aspects of project development, including drafting startup and administrative documents for the project company, negotiating of supply agreements and other contracts, and identifying and resolving permitting issues.
- Negotiated a settlement via mediation of liability for environmental contamination cleanup costs on behalf of a large paper manufacturer, resulting in savings of several million dollars on behalf of the client.
Speaking Engagements and Publications
- Contributor, Troutman Sanders Washington Energy Report.
- Federal Environmental Law Update (May 2012), Environmental & Land Use Law Newsletter, Washington State Bar Association, Vol. 39 Issue 1 pp. 16, May 1, 2012.
- Clean Water Act Section 401 - State Certification, Environment, Energy and Resources Law: The Year in Review 2011, American Bar Association (2012), pp. 148, May 1, 2012.
- Federal Environmental Law Update (Dec. 2011), Environmental & Land Use Law Newsletter, Washington State Bar Association, Vol. 38 Issue 3 pp. 7, December 1, 2011.
- Federal Environmental Law Update (June 2011), Environmental & Land Use Law Newsletter, Washington State Bar Association, Vol. 38 Issue 1 pp. 9, June 1, 2011.
- Protecting Tribal Fishing Rights: Fixing Culverts that Block Fish Passage, The Water Report, Issue 81 pp. 22, November 15, 2010.
- Co-presenter, "Environmental Case Law Update" - 2014 Environmental and Land Use Law Midyear Meeting & Conference, Washington State Bar Association, Cle Elum WA, May 1, 2014.
- "Significant Developments in Environmental Law Over the Past Year, and Implications for Environmental Practitioners in 2012" - KCBA Environmental & Land Use Section's January Brown Bag CLE: 2011 Environmental Law Update and What to Expect in 2012, January 25, 2012.
Professional and Community Involvement
- Energy Bar Association
- Oregon State Bar, Energy, Telecom & Utility Law Section
- Associate, Troutman Sanders LLP, 2015-present
- Associate, Van Ness Feldman LLP, 2010-2015
- Seattle University, J.D., cum laude, 2010
- University of Washington, B.A., 2007