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Bruce Richardson specializes in regulatory and transactional aspects of energy law. A partner in our Energy and Corporate practices, Bruce represents energy sector clients in a variety of transactions, regulatory matters, administrative litigation, and project issues.

Bruce advises and represents independent power producers; merchant transmission developers; electric power marketers; energy asset managers; private equity firms in the energy sector; and generation-owning industrial companies. He counsels these clients on a broad range of transactional issues, regulatory matters, administrative litigation, and project issues. Bruce routinely appears before the Federal Energy Regulatory Commission on regulatory matters and in administrative litigation.

On transactional issues, Bruce advises clients regarding electric power contracts; organized power markets; market-based rates and cost-based rates; interconnection; transmission access; and mergers and acquisitions. He provides guidance on regulatory matters, including issues arising under the Federal Power Act, the Public Utility Regulatory Policies Act of 1978, the Public Utility Holding Company Act of 2005 and the Energy Policy Act of 2005. His administrative litigation includes compliant proceedings and rate proceedings. His project experience includes legal support for development, operation and management of generation projects for clients in numerous states.

Bruce has been recognized numerous times by leading publications, including Legal 500, Chambers Global and Chambers USA, in the area of energy and natural resources.

Full Bio

Credentials

B.A., University of Chicago

J.D., George Washington University, with honors

District of Columbia

Maryland

Virginia

"The highly regarded Bruce Richardson offers clients counsel on reliability and NERC relations, cost-based ratemaking, compliance and transmission issues."


Chambers USA, 2016 and Chambers Global, 2017

Energy Practice


Legal 500, 2016

Matters

Regulatory Representation. Represent clients in connection with utility restructuring; affiliated utility issues; regional transmission organizations; reliability procedures; transmission access and pricing (including service over the ERCOT DC ties); ancillary services; organized power markets; market-based rate proposals; power supply purchases and sales; retail wheeling; independent power production; wholesale electric customer disputes; and interconnection matters.

Regulatory Compliance. Advise clients on regulatory compliance matters, including FERC-exempt wholesale generator activities; electronic quarterly report compliance; separation of functions; and FERC Standards of Conduct requirements. Representation of clients before FERC on regulatory compliance, including Standards of Conduct and open-access transmission policies.

Regulatory Investigations. Represent clients in non-public investigations before FERC.

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Matters

Regulatory Representation. Represent clients in connection with utility restructuring; affiliated utility issues; regional transmission organizations; reliability procedures; transmission access and pricing (including service over the ERCOT DC ties); ancillary services; organized power markets; market-based rate proposals; power supply purchases and sales; retail wheeling; independent power production; wholesale electric customer disputes; and interconnection matters.

Regulatory Compliance. Advise clients on regulatory compliance matters, including FERC-exempt wholesale generator activities; electronic quarterly report compliance; separation of functions; and FERC Standards of Conduct requirements. Representation of clients before FERC on regulatory compliance, including Standards of Conduct and open-access transmission policies.

Regulatory Investigations. Represent clients in non-public investigations before FERC.

Regulatory Policy. Draft comments in connection with federal and state policy statements and rulemakings. Appear on behalf of clients in connection with development of regulatory policy. Participate in litigated proceedings in the formation of regulatory policy.

Transaction Support. Regularly assist clients in obtaining regulatory approvals in connection with power plants, mergers, asset sales, and asset acquisitions.

Electric Reliability. Consult with clients on compliance with the North American Electric Reliability Corporation electric reliability standards and requirements. Represent clients on registration issues at the NERC regional level, at NERC, and before FERC. Negotiate at the NERC regional level both the applicability of and compliance with reliability standards and requirements.

Rate Litigation. Assist clients in the development of cost-based rate filings for services subject to FERC jurisdiction. Appear before FERC in reactive service proceedings, reliability must-run, and transmission rate proceedings. Advise and represent clients in all facets of regulatory hearing process, including settlement, discovery, depositions, testimony preparation, witness preparation, hearing strategy, cross-examination and briefing.

Contract Termination. Represent clients in challenges to existing wholesale electric service contract arrangements in litigated proceedings before FERC.

Merger Litigation. Represent clients before FERC in complex merger proceedings.

Long-Term Power Agreements. Negotiation and drafting of long-term power agreements.

Master Agreements/Proprietary Agreements. Negotiation and drafting of terms and conditions under power master agreements and propriety agreements; gas master agreements and propriety agreements; coal master agreements and propriety agreements; and derivative master agreements. Contract review of energy commodity contracts for pre-bankruptcy energy trading companies. Post-bankruptcy negotiations for liquidation of energy trading companies.

Security Arrangements. Negotiation and drafting of security arrangements, including guaranties, letters of credit, prepayment and lockbox arrangements for energy trading client and project development clients.

Retail Supply Arrangements. Development of proprietary master agreement and supporting security arrangements for use by energy trading client with retail suppliers in retail electric market.

Interconnection Agreements. Representation of utilities and independent power producers on interconnection matters, including negotiation of interconnection agreements.

Mergers and Acquisitions. Representation of independent power, private equity and industrial company acquisition and sale of electric generating assets. Representation of utilities in mergers, including the first three-way electric utility merger.

Project Development. Support clients in the development of electric generation projects in numerous states. Advise on responses to requests for proposals. Negotiate project contracts, including real property acquisition and easements, equipment procurement, supply contracts, interconnection, and power sales.

Project Operation and Management. Advise generating facilities on contract issues, including procurement, contract disputes, and operation and maintenance contracts. Support clients on asset management issues.

Matters

Regulatory Representation. Represent clients in connection with utility restructuring; affiliated utility issues; regional transmission organizations; reliability procedures; transmission access and pricing (including service over the ERCOT DC ties); ancillary services; organized power markets; market-based rate proposals; power supply purchases and sales; retail wheeling; independent power production; wholesale electric customer disputes; and interconnection matters.

Regulatory Compliance. Advise clients on regulatory compliance matters, including FERC-exempt wholesale generator activities; electronic quarterly report compliance; separation of functions; and FERC Standards of Conduct requirements. Representation of clients before FERC on regulatory compliance, including Standards of Conduct and open-access transmission policies.

Regulatory Investigations. Represent clients in non-public investigations before FERC.

See more
Icon close

Close

Matters

Regulatory Representation. Represent clients in connection with utility restructuring; affiliated utility issues; regional transmission organizations; reliability procedures; transmission access and pricing (including service over the ERCOT DC ties); ancillary services; organized power markets; market-based rate proposals; power supply purchases and sales; retail wheeling; independent power production; wholesale electric customer disputes; and interconnection matters.

Regulatory Compliance. Advise clients on regulatory compliance matters, including FERC-exempt wholesale generator activities; electronic quarterly report compliance; separation of functions; and FERC Standards of Conduct requirements. Representation of clients before FERC on regulatory compliance, including Standards of Conduct and open-access transmission policies.

Regulatory Investigations. Represent clients in non-public investigations before FERC.

Regulatory Policy. Draft comments in connection with federal and state policy statements and rulemakings. Appear on behalf of clients in connection with development of regulatory policy. Participate in litigated proceedings in the formation of regulatory policy.

Transaction Support. Regularly assist clients in obtaining regulatory approvals in connection with power plants, mergers, asset sales, and asset acquisitions.

Electric Reliability. Consult with clients on compliance with the North American Electric Reliability Corporation electric reliability standards and requirements. Represent clients on registration issues at the NERC regional level, at NERC, and before FERC. Negotiate at the NERC regional level both the applicability of and compliance with reliability standards and requirements.

Rate Litigation. Assist clients in the development of cost-based rate filings for services subject to FERC jurisdiction. Appear before FERC in reactive service proceedings, reliability must-run, and transmission rate proceedings. Advise and represent clients in all facets of regulatory hearing process, including settlement, discovery, depositions, testimony preparation, witness preparation, hearing strategy, cross-examination and briefing.

Contract Termination. Represent clients in challenges to existing wholesale electric service contract arrangements in litigated proceedings before FERC.

Merger Litigation. Represent clients before FERC in complex merger proceedings.

Long-Term Power Agreements. Negotiation and drafting of long-term power agreements.

Master Agreements/Proprietary Agreements. Negotiation and drafting of terms and conditions under power master agreements and propriety agreements; gas master agreements and propriety agreements; coal master agreements and propriety agreements; and derivative master agreements. Contract review of energy commodity contracts for pre-bankruptcy energy trading companies. Post-bankruptcy negotiations for liquidation of energy trading companies.

Security Arrangements. Negotiation and drafting of security arrangements, including guaranties, letters of credit, prepayment and lockbox arrangements for energy trading client and project development clients.

Retail Supply Arrangements. Development of proprietary master agreement and supporting security arrangements for use by energy trading client with retail suppliers in retail electric market.

Interconnection Agreements. Representation of utilities and independent power producers on interconnection matters, including negotiation of interconnection agreements.

Mergers and Acquisitions. Representation of independent power, private equity and industrial company acquisition and sale of electric generating assets. Representation of utilities in mergers, including the first three-way electric utility merger.

Project Development. Support clients in the development of electric generation projects in numerous states. Advise on responses to requests for proposals. Negotiate project contracts, including real property acquisition and easements, equipment procurement, supply contracts, interconnection, and power sales.

Project Operation and Management. Advise generating facilities on contract issues, including procurement, contract disputes, and operation and maintenance contracts. Support clients on asset management issues.

Credentials

B.A., University of Chicago

J.D., George Washington University, with honors

District of Columbia

Maryland

Virginia

"The highly regarded Bruce Richardson offers clients counsel on reliability and NERC relations, cost-based ratemaking, compliance and transmission issues."


Chambers USA, 2016 and Chambers Global, 2017

Energy Practice


Legal 500, 2016