Carrie represents investor-owned and non-jurisdictional utility clients, as well as competitive retail electric and natural gas supplier clients on a variety of matters before the Federal Energy Regulatory Commission (FERC) and state commissions. She has experience with various wholesale electric matters, including Regional Transmission Organizations (“RTO”) and Independent System Operators (“ISO”) market design, RTO/ISO market alternatives, transmission planning and cost allocation, generator interconnection issues, and compliance issues arising across the FERC spectrum.  Carrie has significant experience representing utility clients in administrative litigation before FERC, including filing complaints and comments, and participating in hearings and settlement proceedings before FERC.

Carrie also regularly advises competitive retail electric and natural gas suppliers in unbundled retail markets on compliance matters, and provides related transactional support, including advising licensed suppliers on required post-closing notices and filings.

Carrie is also deeply invested in pro bono efforts, having won the 2020 D.C. Office “Closing the Justice Gap” award for her pro bono service.  Carrie’s pro bono practices focus primarily on immigration (asylum and refugee) issues, and veterans’ issues.

Wholesale Market Tariffs and Market Design

  • Representation of group of utilities successfully creating a first-of-its kind market platform in the Southeastern United States extending to parts of 12 states and across two time zones, including representation in multi-year litigation before FERC and the District of Columbia Circuit Court of Appeals (“D.C. Circuit”) involving multiple novel procedural and legal issues
  • Representation of a public utility in two fully litigated proceedings before FERC relating to a proposal to implement a new imbalance services market and associated market cost allocation construct
  • Representation of various energy clients related to RTO/ISO tariff and market design issues, including with regards to issues of preemption, and with particular emphasis on cost allocation matters and complaints against RTOs or other matters involving proposed changes to RTO tariffs

Transmission Cost Allocation, Planning

  • Representation of a public utility in multiple litigated proceedings before FERC and the D.C. Circuit regarding transmission cost allocation and zonal placement, requiring participation in several multi-day and multi-week hearings before FERC and compliance with FERC’s electronic hearing rules
  • Representation of clients concerning transmission rulemaking proceedings, complaints, and general compliance inquiries regarding transmission planning
  • Representation of clients regarding competitive transmission project solicitations, including assistance with cost containment proposals

Generator Interconnection

  • Representation of clients on generator interconnection issues, including issues related to milestone dates, assignment, and suspension

Compliance

  • Frequently called upon to assist clients in interpreting and complying with RTO/ISO Market Rules and Manuals, and to advocate interpretations of ambiguous rules to RTO/ISO staff and FERC
  • Frequently called upon to assist clients in interpreting and complying with FERC rules and regulations, including on issues related to generator interconnection, transmission planning, and market-based rates

Transactional Support

  • Conducts regulatory and interconnection-related due diligence on energy transactional matters, including due diligence related to licensed competitive electric and natural gas suppliers
  • Manages post-closing regulatory requirements applicable to competitive electric and natural gas suppliers

Events

  • Presenter, "FERC Enforcement Updates," National Energy Compliance Forum, November 9, 2023

Insights

  • Selected for inclusion in Best Lawyers: Ones to Watch, Energy Law, 2024, 2025, 2026