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Katlyn A. Davis Farrell Partner

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Washington, D.C. T +1 202 857 1735 F fax +1 202 828 2994
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Katlyn represents energy and utility clients before the Federal Energy Regulatory Commission (FERC), the North American Electric Reliability Corporation (NERC), and appellate courts. She has broad experience on electric matters, including matters related to cost-based and market-based rates; generator interconnection; RTO/ISO issues including RTO/ISO tariffs, cost allocation, and market design. Additionally, Katlyn provides transactional support, including obtaining required FERC, NERC, and RTO/ISO approvals.

Katlyn also counsels clients on FERC compliance and enforcement matters, with an emphasis on the FERC Standards of Conduct, Affiliate Restrictions and Cross Subsidization Rules, Electric Quarterly Reports, Interlocking Directorates, and Order No. 860 relational database requirements.

Katlyn is active in the firm’s pro bono efforts and is currently the Pro Bono Lead for the D.C. Office. In her pro bono practice, she primarily focuses on asylum and immigration issues. Since 2014, Katlyn represented a young mother who fled Cameroon to escape her violent husband, a high-ranking military official, by obtaining asylum for her and her daughter who remained in hiding in Cameroon, finally obtaining permanent resident status for mother and daughter in 2023. In 2018, Katlyn was part of a team that secured a record-breaking civil judgement for a victim of human trafficking.

Experience

Electric Rate Experience

  • Representation of electric utility clients in transmission cost-of-service ratemaking matters, including experience with stated and formula rates, and transitions from stated to formula rates.
  • Representation of companies seeking to obtain and maintain market-based-rate authority.
  • Representation of companies seeking generation cost-of-service rates for generators providing out-of-market “reliability-must-run” service, including a first-of-its-kind case for cost-of-service compensation to a generator for providing fuel security.
  • Representation of companies seeking cost-of-service rates for provision of reactive power services.

Transactional Support

  • Advised major U.S. electric developer in restructuring ownership of over 4,000 MW of generating assets, including obtaining FERC 203 approval, MBR authorization and EWG status for new project companies, and making required RTO compliance filings.
  • Advised publicly-held generation developer in making all filings needed in connection with “spin” transaction where it was separated from investor-owned utility affiliates.
  • Regularly advises clients on FERC, NERC, and RTO/ISO requirements necessary to effectuate transactions involving FERC-jurisdictional assets and companies, including corporate reorganizations.
  • Conducts regulatory and interconnection-related due diligence on energy transactional and financing matters and advises on purchase and sale agreements.

RTO/ISO Tariff and Market Design

  • Representation of group of utilities creating a first-of-its kind market platform in the Southeastern United States extending to parts of 12 states with more than 180,000 MWs (summer capacity; winter capacity is nearly 200,000 MWs) across two time zones.
  • Representation of a utility in taking a leading role for Southwest Power Pool (SPP) transmission owners in a first-of-its-kind multi-party litigation involving whether one regional transmission operator, Midcontinent Independent System Operator, Inc. (MISO), should pay another, SPP, for use of SPP’s system resulting from MISO’s dispatch of its generation.
  • Representation of a generation owner in a first-of-its-kind complaint proceeding involving whether a regional transmission organization (RTO) should compensate a generator for gas that the RTO directed the generator to purchase, even though the gas was not used to produce power.
  • Representation of clients with RTO tariff, market design, and cost allocation matters, including assisting RTO participants in a variety of postures, including complaints against RTOs and challenges of proposed changes to RTO tariffs.
  • Representation of clients in appellate proceedings before the Sixth Circuit and District of Columbia Courts of Appeals involving RTO issues.

Compliance and Enforcement

  • Counsels clients on both FERC and NERC compliance matters, including compliance with FERC Standards of Conduct, Affiliate Restrictions, MBR related requirements, Interlocking Directorates, Market Manipulation rules, and NERC Reliability Standards.
  • Partnered with the Edison Electric Institute to develop their reboot of Standards of Conduct and Market Manipulation training in 2016.
  • Regular contributor and supporter of the National Energy Compliance Forum (NECF), an organization devoted to sharing best practices for FERC compliance.

NERC

  • Assisted clients in NERC audit and enforcement actions with responding to Regional Entities (including RFC, SERC, and AESO) regarding notices of alleged violations of NERC Reliability Standards.
  • Advises clients on NERC compliance issues, including significant experience advising on NERC’s Critical Infrastructure Protection (CIP) Standards.

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