Experience
Representative Work
Data Center & Large Load
- Advised data center developers, large power purchasers, and utilities on interconnection strategy and power procurement for large new loads in the Western U.S. and Texas.
- Drafted study agreements for a data center developer in connection with project development.
- Advised an electric utility on the state and FERC regulatory treatment of potential power supply structures, including sleeve PPA arrangements, for serving a data center customer.
- Advised on SPP and MISO generation interconnection processes as they affect large-load and data center projects.
- Analyzed FERC regulatory treatment of islanded and co-located load configurations serving large loads.
- Analyzed bulk power system reliability considerations related to large load interconnection in connection with NERC Large Loads Task Force proceedings and FERC Docket No. RM26-4.
- Advised clients on Utah's 2025 large load law (S.B. 132), including commission approval of a data center's large load service contract and registration of large-scale generation providers.
- Advised a generation and transmission cooperative on affiliate restrictions and counterparty risk in serving a large cryptocurrency mining load.
FERC & Interconnection
- Conducted FERC regulatory analysis of interconnection rights in connection with generation replacement projects, including queue position preservation considerations.
- Advised electric utilities and independent power producers on FERC jurisdictional issues under the Federal Power Act, including market-based rate authority, exempt wholesale generator status, and FPA Sections 203 and 205 compliance.
- Analyzed FERC filing obligations under FPA Section 205 for administrative agent and escrow agreements in connection with transmission coordination arrangements.
- Prepared FPA Section 205 filings for transmission and interconnection agreements in MISO, including agreements for a jointly developed 345 kV transmission line and a 200 MW battery storage project.
- Advised utilities and transmission developers on merchant transmission rate authority, MISO capacity accreditation, FERC affiliate restrictions, interlocking directorate requirements, and the filed rate doctrine.
State Utility Commission Proceedings
- Drafted large load service contract applications and rate case testimony before state utility commissions.
- Advised on Idaho Public Utilities Commission regulatory jurisdiction and approval requirements under Title 61 in connection with utility-scale solar project development and power purchase agreements.
- Represented an investor-owned utility in a contested certificate of public convenience and necessity case before the North Dakota Public Service Commission against a rural electric cooperative over service to a wind farm.
- Represented investor-owned utilities in rate cases before the North Dakota Public Service Commission and the New Mexico Public Regulation Commission.
- Represented investor-owned and vertically integrated utilities in certificate of convenience and necessity (CCN) and rate cases before the Public Utility Commission of Texas (PUCT) and other state commissions.*
- Represented various utilities before the PUCT on transmission and generation capital investment approvals.*
- Advised Texas utilities on system resiliency and wildfire mitigation plans, power purchase agreements, the Lone Star Infrastructure Protection Act, and state legislation and commission rulemaking.*
Power Contracting, Project Finance & Transactions
- Drafted state energy regulatory opinions and accompanying memorandums across multiple jurisdictions — including Utah, Washington, Montana, Colorado, Idaho, and Arizona — advising on state utility commission jurisdiction over independent power producers and exempt wholesale generators in connection with renewable energy and battery storage project financings.
- Drafted energy regulatory covenant provisions in renewable energy project financing agreements, including pre-generation compliance obligations and regulatory representations.
- Advised on power purchase agreement structures, including model PPAs, sleeve PPA arrangements, and backstop agreements.
- Drafted model power purchase agreements for an electric utility.
- Advised on tax equity transaction structures for renewable energy projects, including voting and consent rights analysis and partnership law research.
- Advised a wholly regulated electric utility on FPA Sections 203 and 205 compliance in connection with a joint ownership agreement.
- Advised a developer on the secured financing of a three-state wind repowering portfolio, including the Washington, Montana, and Colorado regulatory opinions and the regulatory provisions of the financing agreement.
- Advised lenders on state energy regulatory diligence for utility-scale solar financings in Arizona and Utah.
- Advised a developer on state energy regulatory matters in its acquisition of solar project companies in California and Nevada.
- Advised an investor on buy-side diligence for a minority equity investment in a Nevada copper mining company.
- Drafted project and financing documents, including interconnection cost reimbursement, right-of-way consent and non-disturbance, mortgage modification, and pole attachment agreements.
- Served as lead associate on a Section 45Z clean fuel production credit opinion for a biodiesel producer transferring its credits under Section 6418.
*Experience occurred prior to joining Dorsey.
Pro Bono
- Representing a rural water and sewer district in connection with local regulatory and governance matters.
- Externship for ACLU of Florida.

