Jane Rueger

Clearway Energy, Inc.

Represent leading publicly-traded energy infrastructure investor, in related transactions in which it acquired equity interests in a 1,204 MW portfolio of renewable energy projects, including five geographically diversified wind, solar, and solar-plus-storage assets, and formed a joint venture with Hannon Armstrong, a leading climate-solutions investor, through which Clearway and Hannon, to co-invest in the development of the portfolio, with Clearway as manager of the joint venture and the renewable energy projects.

FERC Regulatory Implications of Tax Equity Partnerships

Advise several large electric utilities with regard to FERC implications of various tax equity partnership structures, including application of FPA Section 203 and affiliate restrictions.

Corporate Carbon-Free Energy Procurement & Policy

Represent corporate offtakers in the negotiation of power purchase and sale agreements (both physical and virtual) for solar, wind and other carbon-free energy resources in power markets around the United States, as well as innovative transactions related to carbon capture and storage, synthetic community solar, and complex sleeved retail supply arrangements.

FERC Market-Based Rate Authority

Advise generators, power marketers, and large electric utilities with regard to obtaining and maintaining market-based rate authority from FERC and associated regulatory compliance.

Generator Interconnection

Negotiate generator interconnection agreements for large gas-fired and wind/solar generators in MISO and NYISO markets. Advise clients regarding implications of changes to the pro forma interconnection agreements and procedures over time, including with respect to reliability obligations.

Electric Vehicle Regulatory Policy – Nationwide

Advising large electric vehicle manufacturer on policy engagement to promote EV adoption and reduce barriers to implementing V2G applications in multiple states and with respect to federal agencies across the country.

EV Charging Infrastructure Contracts – Nationwide

Representing distributed energy provider with regard to negotiation of contracts for procurement of EV charging infrastructure for deployment at various sites as well as negotiation of contracts to supply EV charging infrastructure at various real estate developments across the country.

FERC Winter Storm Elliott Complaints

Representing developer of renewable energy and demand response assets in the PJM market with regard to multiple complaints filed against PJM for imposition of capacity performance penalties due to failure to operate during Winter Storm Elliott.

QF Litigation and Compliance

Represent large electric utility with regard to litigation over the obligation under the US Public Utility Regulatory Policies Act of 1978 to purchase power from qualifying facilities at the electric utility’s avoided cost rate. Advise owners of qualifying facilities under PURPA with regard to FERC regulatory compliance, including obtaining and maintaining self-certifications and waivers from certain requirements.

Natural Gas Regulatory Compliance

Represent an LDC (a Hinshaw pipeline) and its affiliated gas storage provider with regard to all aspects of FERC compliance, including jurisdictional analysis of proposed transactions, SOC / OS maintenance and market-based rate compliance, advice on and submission of FERC filings related to new products and services, and representation in interstate gas pipeline rate proceedings before FERC.

Firm Interstate Pipeline Capacity Transactional Compliance

Advise LDCs, generators and energy marketers with regard to compliance with FERC AMA requirements and other FERC shipper considerations.

FERC Approvals Associated With M&A Transactions

Represent generators, investment funds, governmental entities and others with respect to application of FPA Section 203 to complex M&A transactions, as well as FERC regulations and filings applicable to complex reorganizations. Advise firm interstate pipeline capacity holders regarding need for FERC waivers or other approvals in connection with asset sales and mergers and acquisitions, and submission of applications for waivers and approvals where required.

Jurisdictional Analysis

Advise multiple large oil and gas producers with regard to FERC jurisdiction over natural gas gathering and production facilities and associated intrastate pipeline systems.

FERC Presidential Permits

Secured approval of Presidential Permits for natural gas export facilities into Canada.*

FERC Oil Regulation

Advised infrastructure fund with respect to federal regulatory considerations associated with its over US$1.8 billion acquisition of one of the largest, privately held crude oil transportation systems in West Texas. Negotiated terms of a joint tariff agreement between two interconnected crude oil transportation systems.*

Electric Storage Services Agreements

Represented large investor owned utility in the negotiation of energy storage services agreements to meet energy storage mandates, as well as renewable power purchase agreements to meet the utility’s RPS mandates, in the California electricity markets.*

*Prior experience