Our lawyers have represented large energy customers across the full spectrum of regulatory matters arising before state public utility commissions, with a particular emphasis on rate and rulemaking proceedings. We work hand in hand with clients’ key executives, senior managers, technical staff, and outside consultants and draw on our in-depth understanding of cost-of-service ratemaking principles to gather the necessary data to support or challenge rate requests. We also advise clients in sophisticated ratemaking matters, including nuclear plant and nuclear waste write-offs and phase-ins, utility divestitures, curtailments and gas diversions, rate design, standby rates, avoided costs, special load retention, and economic development rates for industrial customers.
When rate decisions are counterproductive, we help clients mount an effective challenge. We advise clients at every step, from initial discovery to settlement negotiations and, when necessary, in litigation. We also provide advice and assistance in a variety of other proceedings, including investigations, complaint cases, and power supply cost-recovery actions.
We have helped numerous clients identify and implement innovative solutions that have reduced their utility spend. These include advocating for gas transportation and retail choice (or open access), increasing leverage through the creation of new energy source alternatives that bypass local gas and electric utilities, negotiating special-rate contracts, and developing and negotiating interruptible tariffs that permit customers to back up their utility-supplied interruptible electric service. Our efforts in this regard have quite literally saved our clients hundreds of millions of dollars.