Andrea Chambers
Of CounselAndrea Chambers focuses her practice on energy regulation and project finance. She has 30 years of experience on matters before the Federal Energy Regulation Commission (FERC) and has advised on wholesale electric energy markets, natural gas pipelines, and electric.
Andrea has represented utilities in restructuring of electricity markets and advised transmission owners regarding all aspects of electric rates and tariffs and assisted renewable generators in matters regarding interconnection with RTO and ISOs in all regions of the country. She has obtained market-based rate authorization for generation owners and advised renewable generation owners on qualifying facility status and exempt wholesale generation requirements regarding PUHCA.
Andrea has prepared FPA Section 203 applications on behalf of clients for transfers of FERC-jurisdictional assets and has provided strategic advice regarding blanket authorizations available for such transfers. She has advised clients regarding transfers of generation and transmission assets in Texas subject to the jurisdiction of the Public Utility Commission of Texas. Her advice in these transactions often involves state energy regulatory compliance.
Andrea also has extensive experience counseling clients regarding compliance with FERC compliance and enforcement matters.
In her practice, Andrea also provides advice on DOE matters, concerning presidential permits for building cross-border facilities and import and export authorization. She has counseled clients building subsea transmission cables.
In addition to her electric regulatory practice, Andrea also has an extensive practice before FERC representing shippers on natural gas pipelines.
EXPERIENCE
Electric industry
- Advised multiple electric industry clients regarding power sales and transmission contracts, obtaining market-based rate authorizations and merger approvals, filing for EWG status and QF filings
- Advised interconnecting solar, battery, geothermal and wind developers regarding all aspects of generation interconnection procedures, including interconnections in all ISO and RTO markets
- Advised investors in an offshore electric transmission grid on regulatory issues
- Served as lead litigation counsel for various entities in connection with the California energy crisis litigation as well as related Pacific Northwest proceedings regarding allegations of market manipulation
- Prepared internal enforcement compliance manuals for electric utilities, providing compliance training and defending clients in enforcement proceedings
- Served as lead litigation counsel for a Missouri electric utility in proceedings regarding reactive power payments
- Represented a power marketing entity in a case involving capacity payments in organized markets
- Guided a Florida utility in the formation of Transco and in obtaining merger approvals
- Represented an investor in energy projects regarding regulatory aspects of asset sale
- Advised financial institution in providing third-party clearing services to RTO
- Counseled a NERC sub-regional council regarding dispatch procedures
- Represented a midwestern electric utility regarding open access transmission, including compliance with Order 1000, preparing transmission service agreements and interconnection agreements, and all aspects of transmission planning and NERC compliance, including filing of tariffs to establish ITO
- Acted as regulatory counsel to eight utilities in New York state in obtaining regulatory approvals for startup of the NYISO, including filing of transmission and market tariffs
Transactional
- Represented a client in all regulatory aspects of a self-generation incentive program and demand energy resource asset payment under California law and all federal regulatory issues in a landmark transaction for financing of a portfolio of battery storage systems in California
- Provided strategic regulatory advice regarding federal and state approvals for implementing internal reorganization designed to facilitate a portfolio financing of nearly all of the company's renewable projects
- Guided a client in regulatory approvals for an internal corporate restructuring involving establishing new SPV to transfer ownership of four different gas-fired generation assets in preparation for a sale of assets
- Aided clients in achieving functional unbundling of gas-fired and hydro generation assets from transmission and establishing independent transmission to operate a transmission system on a non-discriminatory basis and administer least-cost bid-based energy auction markets while allowing the owners of generation and transmission to retain ownership and control of such assets
- Obtained approvals for transfer of control of jurisdictional assets at state and federal levels in support of transactions for purchases and sales of renewable and fossil-fired electric generation
- Advised a client in financing involving distributed energy solar and battery resources under state incentive programs
Natural gas
- Served as counsel to an association of natural gas shippers on regulatory issues
- Actively participated in FERC hearing and settlement proceedings involving natural gas transportation rates on behalf of large LDCs
- Represented an underground storage project in obtaining certificate approvals
- Conducted annual FERC compliance training and established in-house compliance programs for natural gas producers, traders and end users
- Prepared comments on industry-wide rulemakings regarding income tax allowances and price indices
- Advised an LNG development client on issues regarding development of new liquefied natural gas facilities, including DOE and FERC approvals
- Served as in-house counsel for a combined natural gas and electric company, advising five pipeline company subsidiaries on natural gas certificate, rate, and compliance issues
- J.D., American University
- B.S., Georgetown University
Awards
The Legal 500 United States
- Recommended, Energy: Renewable/Alternative Power (2023)
Chambers Global
- Band 5, USA Energy: Oil & Gas (Regulatory & Litigation) (2023 – 2024)
Chambers USA
- Band 5, Nationwide Energy: Oil & Gas (Regulatory & Litigation) (2023 – 2024)
