Overview
Daniel’s practice spans the full energy project lifecycle — from FERC interconnection strategy and wholesale market compliance to power purchase agreement drafting, state regulatory opinions in connection with project financings, and proceedings before the Utah PSC, New Mexico PRC, and other state commissions. He has developed particular depth in interconnection processes, including advising clients on SPP’s newly approved Consolidated Planning Process and MISO’s Definitive Planning Process.
Daniel advises independent power producers and project developers 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. He also advises on power purchase agreement structures, project financing regulatory matters, and tax equity transactions for renewable energy projects. Daniel also serves data center developers and large power purchasers on interconnection strategy and power procurement in the Western U.S. and Texas.
Education & Admissions
Cornell Law School (J.D., 2022),
- President, First Generation Student Association
- 2021 Transactional Lawyering Competition Winner, Buyer’s Side
- 2021-22 Seymour Herzog Memorial Prize Winner
Florida International University (B.A., Political Science & English, 2016),
- Andre Dawson Scholarship Recipient
- Major League Baseball Clubhouse Manager Association Scholarship Recipient
Admissions
- Texas
- Not admitted in Utah. Admitted in Texas.
Languages
- Spanish
Experience
Representative Experience
FERC & Interconnection
- Advised energy developers on changes in interconnection processes, including SPP’s Consolidated Planning Process and MISO’s Definitive Planning Process.
- Conducted FERC regulatory analysis of interconnection rights in connection with generation replacement projects, including queue position preservation considerations.
- Advised 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 for electric utilities and independent power producers.
- Analyzed FERC filing obligations under FPA Section 205 for administrative agent and escrow agreements in connection with transmission coordination arrangements.
- Advised on FERC regulatory treatment of islanded load configurations.
- Analyzed bulk power system reliability considerations related to large load interconnection in connection with NERC Large Load Task Force proceedings and FERC Docket No. RM26-4.
State Utility Commission Proceedings
- Drafted large load service contract applications and rate case testimony before state utility commissions.
- Advised on Idaho public utility commission regulatory jurisdiction and approval requirements under Title 61 in connection with utility-scale solar project development and power purchase agreements.
- Represented investor-owned and vertically integrated utilities in CCN and rate cases in Texas. *
- Represented various utilities before the Texas Public Utility Commission (PUCT) on transmission and generation capital investment approvals. *
- Advised Texas utilities on system resiliency plans, power purchase agreements, and state legislation and commission rulemaking. *
* Experience occurred prior to joining Dorsey.
Power Contracting, Project Finance & Transactions
- Drafted and assisted in drafting state energy regulatory opinions and accompanying memorandums across multiple jurisdictions, including Utah, Washington, Montana, and Idaho in connection with renewable energy project financings, advising on state utility commission jurisdiction over independent power producers and exempt wholesale generators.
- Assisted in drafting 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.
- 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.
Pro Bono
- Representing a rural water and sewer district in connection with local regulatory and governance matters.
- Externship for ACLU of Florida
Judicial Externship
- U.S. District Court for the Eastern District of New York, Judge Joan M. Azrack, 2021
