Larry has served as lead outside counsel assisting clients with a variety of matters that involve energy regulation, including:
- Appeals of FERC Orders. Recent examples include:
- Challenges in the D.C. Circuit to FERC orders assessing RTEP costs to NYPA (pending);
- Challenges in the D.C. Circuit to FERC hydropower orders respecting federal pre-emption of state regulation (pending);
- Argument in MRES v. FERC (D.C. Circuit), 918 F.3d 954 (2019);
- Argument in Portland General Electric Co. v. FERC, 854 F.3d 629 (2017); and
- Argument in Ninth Circuit in Idaho Power Co, v. FERC, 801 F.3d 1055 (2015).
- The regulatory and commercial component of due diligence for potential investors in infrastructure projects;
- Negotiation of precedent and other commercial and operating agreements:
- Authorizations for LNG, pipeline, and hydropower projects, some of which have been contested;
- Enforcement investigations and compliance planning;
- Agency evidentiary proceedings; and
- Acting as regulatory counsel in civil litigation in which FERC issues are present.
Larry’s work encompasses natural gas, electric, and appellate matters. He was lead rate and tariff counsel for the Panhandle Eastern family of interstate pipelines, an active participant in the development of LNG terminals for a variety of companies and investors, regulatory counsel in the multi-party Louisiana coastal wetlands civil litigation against the oil and gas industry, and served as lead FERC counsel for the Hells Canyon hydropower project. He also was lead counsel for more than four years for the power marketers in FERC's California refund proceedings, and related appeals, including presenting oral argument before the Ninth and D.C. Circuits; and he was in the leadership group of the Marketers in FERC's Pacific Northwest refund proceedings, including arguments challenging FERC before the Ninth Circuit, resulting in the remand of FERC’s Orders.
He represented the California ISO in connection with prominent market manipulation matters and to block interference with the ISO’s efforts to prevent load shedding during summer peak periods in Southern California.