Gregory K. Lawrence

Phone212 504 6171

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Practice Areas

  • Business Fraud & White Collar Defense
  • Commodities & Futures Regulation
  • Corporate
  • Energy & Commodities
  • Energy & Commodities Investigations
  • Swap Regulation
  • Energy & Commodities Regulation & Compliance
  • Energy & Commodities Transactions
  • Financial Regulation
  • Litigation
  • Renewables
Contact InfoTelephone: 212 504 6171
Fax: '202 862 2400
University Trinity College, B.A., 1988
Law SchoolNew England School of Law, J.D., 1991
Admitted1991, Massachusetts; 1993, District of Columbia; New York; U.S. Court of Appeals, District of Columbia Circuit; U.S. Supreme Court

Gregory K. Lawrence focuses on the electricity and natural gas industries, with extensive experience before the Federal Energy Regulatory Commission (FERC) and multiple state utility commissions regarding regulatory proceedings, compliance and enforcement, transactions and negotiations, asset transfers, and governmental affairs. His clients include financial institutions and funds, marketers, traders, renewable and other project developers, municipal and investor-owned utilities, and large energy consumers.

Recognized as a leading energy and electricity lawyer by Chambers USA, Greg is a frequent speaker at energy industry conferences and a contributor to a wide range of publications, including The Electricity Journal, Electric Light & Power, Energy Risk, Bloomberg Law Reports, Project Finance International, Corporate Counsel, Windpower Engineering, and EnergyLaw 360. He is also the author of a quarterly column in Electric Energy T&D Magazine and of “Rationalizing Supply with Demand: Electricity Demand Response in U.S. Wholesale Electricity Markets,” a book chapter in US Law and Taxation (Cameron May). He has taught energy seminars at the Massachusetts Institute of Technology Sloan School, Cornell Law School, and Syracuse University. Greg recently presented at The Harvard Kennedy School, Harvard Electricity Policy Group, regarding electricity market manipulation legal issues.

A former counsel with the Massachusetts Department of Public Utilities, he is a member of the Energy Bar Association. Greg is a graduate of Trinity College and the New England School of Law. He is admitted to practice in Massachusetts, New York, the District of Columbia, and before the U.S. Court of Appeals (D.C. Cir.) and the U.S. Supreme Court.

News & Resources


News Releases

Cadwalader Advises Credit Suisse International in Sale of Commodity Transaction Portfolios
Jan 07, 2015

Cadwalader Advises Mercuria Energy Group in Acquisition of JPMorgan's Physical Energy and Commodities Business
Oct 03, 2014

Cadwalader Advises Exelon Corporation in Acquisition of Integrys Energy Services
Jul 30, 2014

Cadwalader Recognized Among Leading Firms in The Legal 500 US 2014
Jun 27, 2014

Cadwalader Advises Mercuria on Acquisition of J.P. Morgan's Energy and Commodities Trading Company
Mar 19, 2014

Cadwalader Recognized for Excellence at 2013 Commodity Business Awards
Nov 21, 2013

Cadwalader Recognized in 2013 Edition of The Legal 500 US
Oct 25, 2013

More Than 25 Cadwalader Attorneys in 17 Practice Areas Recognized by 2013 Chambers Global Guide
Apr 08, 2013

Cadwalader Expands D.C. Office With Launch of Energy and Commodities Advisory Practice
Jan 20, 2011

Recent Press

Early Dissents Hint Future FERC Chair Won't Pull Punches
Oct 02, 2014

CFTC-FERC Deal Leaves Enforcement Question Unanswered
Jan 09, 2014

FERC's Lessons From DC Energy Rehearing Order
Jul 24, 2013


Cadwalader Recognized Among Leading Firms in The Legal 500 US 2014
Jun 27, 2014

Chambers and Partners USA 2014
May 23, 2014

Cadwalader Recognized for Excellence at 2013 Commodity Business Awards
Nov 21, 2013

Cadwalader Recognized in 2013 Edition of The Legal 500 US
Oct 25, 2013

Chambers and Partners USA 2013
May 24, 2013

Chambers and Partners USA 2012
Jun 07, 2012


Clients & Friends Memos

2014 FERC Enforcement Report Emphasizes Internal Compliance Procedures, Self-Reporting, and Importance of Cooperation
Nov 25, 2014

The Fate of FERC Demand Response Order No. 745: Efforts to Adapt While the Judicial and Complaint Processes Play Out
Nov 14, 2014

On to the Supreme Court? The D.C. Circuit Denies FERC's Request for Rehearing En Banc of its Decision to Vacate FERC's Demand Response Rule
Sep 29, 2014

Clear Rift Highlighted by Commissioners' Lack of Action on New England's Most Recent Forward Capacity Auction Results
Sep 24, 2014

Gloves Are Off: FERC Issues Public Notice of Alleged Violations in Powhatan Investigation
Aug 08, 2014

More FERC Federalism: D.C. Circuit Affirms FERC's Jurisdiction Again - New England Power Generators Ass'n v. FERC
Jul 14, 2014

Update Regarding D.C. Circuit's Demand Response Ruling
Jun 16, 2014

EPA Proposes First Carbon Emissions Limits for Power Plants
Jun 04, 2014

D.C. Circuit Vacates FERC's Wholesale Demand Response Compensation Rule Because It Goes Too Far
Jun 02, 2014

FERC Orders Evidentiary Hearing for Alleged Market Manipulation by BP
May 19, 2014

Significant Upwind Impact: The Supreme Court Upholds Cross-State Air Pollution Rule
May 09, 2014

Going Public: Powhatan Energy Fund's “Insurance Policy” Regarding FERC Enforcement's Non-Public Manipulation Investigation into the Fund's “High-Frequency” PJM Trading Activity
May 05, 2014

FERC Enforcement Director Calls for Legislative Fix to Address Hunter Decision
Jan 24, 2014

FERC and CFTC Reach Agreement on Information Sharing and Jurisdiction
Jan 07, 2014

2013 FERC Report Confirms Increased Enforcement Activity
Dec 09, 2013

FERC Denies Rehearing in DC Energy - Clarifies Position on Reportable IBTs and Side Steps Jurisdictional Issue
Jul 16, 2013

FERC Commissioners Receive ISO/RTO Gas-Electric Coordination Reports at Open Meeting, Significant Issues Remain
May 20, 2013

CFTC Issues Final Exemption Order for RTO/ISO Transactions
Apr 03, 2013

First Ever Admission of Violation in FERC Manipulation Action
Nov 20, 2012

FERC Confirms It Lacks Jurisdiction over Unbundled Renewable Energy Certificate Sales
Apr 30, 2012

FERC Issues Orders on MISO Net Zero Interconnection Service
Apr 13, 2012

FERC Finds “More Credible” a Postage Stamp New Transmission Cost Allocation for PJM
Apr 09, 2012

EPA Proposes CO2 Emissions Standards for New Fossil Fuel-Fired Power Generators
Apr 03, 2012

Senator Stabenow's Alternative Energy Tax Incentive Measure Fails to Pass Senate
Mar 19, 2012

Clean Energy Standard Legislation Introduced in Senate
Mar 02, 2012

Duke-Progress Merger Delayed by FERC Ruling; Implementing Tariffs Also Rejected Without Prejudice
Dec 19, 2011

First Time for Everything: Finding Unduly Discriminatory Treatment of Wind Generators and Compelling Circumstances, FERC Exercises Its Section 211A Authority to Order BPA to Change Its Ways
Dec 13, 2011

FERC Issues Order Denying Hunter Rehearing Request on Alleged Market Manipulation
Nov 22, 2011

FERC Office of Enforcement Issues 2011 Report on Enforcement
Nov 22, 2011

FERC Orders Trader to Pay $30 Million for Market Manipulation
Apr 22, 2011


Up In The Air With FERC's Demand-Response Rule
Nov 26, 2014

Confusion Over FERC Rules Will Remain After Powhatan
Jun 11, 2014

Avoiding the 'Al Capone' Trap: The Dangers of Supplying Inaccurate Information to FERC
Nov 01, 2013

FERC Enforcement: The Pit and the Pendulum
Apr 01, 2013

Crippling regulatory uncertainty, overstepping seen in recent FERC enforcement actions
Dec 03, 2012

Generation Investors Step Up to the Plate: What's FERC Pitching?
May 01, 2012

Line Re-Rating: A Bridge Over Generation Interconnection Troubles
Mar 01, 2012

“Excuse Me, But FERC Enforcement Is On the Phone...”
Feb 10, 2012

The Bigger Picture U.S. Renewable Transmission and Interconnection Reform: Can't Get There from Here?
Apr 01, 2011

Gearing Up for GHG Regulation
Jul 01, 2010

To Disclose or Not to Disclose? What is Climate Change's Impact on Your Utility?
Jun 10, 2010

Emerging Paths for Climate Change Regulation in the United States
Jun 01, 2010


Financial Products in Organized Electricity Markets: Convergence, Liquidity, Quants and Uplift
Jan 14, 2015

American Conference Institute's 10th National Forum on Energy Trading Compliance & Regulatory Enforcement
Nov 20, 2014

2014 Charlotte Chamber Energy Summit
Nov 14, 2014

Harvard Electricity Policy Group Seventy-Fifth Plenary Session
Jun 12, 2014

FERC Enforcement 2.0: A Timely Roundtable Discussion
May 21, 2014

ERCOT Market Summit 2014
Feb 24, 2014

ACI's 8th National Forum on Energy Trading Compliance & Regulatory Enforcement
Nov 21, 2013

Platts 6th Annual Nodal Trader Conference
Oct 28, 2013

Energy, Business, Diversity and the Law Symposium
Oct 15, 2013

2013 Energy & Commodities Conference
Oct 10, 2013

Electricity and Natural Gas Coordination: As Winter Approaches, Regulators and the Energy Industry Respond
Oct 08, 2013

Harvard Electricity Policy Group Meeting
Jun 13, 2013


Government Investigations and Compliance

•Represented an energy trading company and individual traders regarding FERC manipulation investigation of relational trading, physical power schedules and congestion revenue rights in Western markets, resulting in no enforcement action
•Represented a trading company and individuals regarding FERC manipulation investigation of schedules and inaccurate information claims in the CAISO market,, resulting in no enforcement action
•Defended energy marketers regarding various FERC enforcement theories involving day-ahead and real-time energy, up-to congestion, virtual, and FTR equivalents transactions, including physical and financial, and fundamental and quantitative trading
•Represented an asset manager/generator regarding CFTC review of generator obligations in ERCOT, resulting in no enforcement action
•Represented financial institution and asset/manager/generator regarding FERC investigation of capacity supply obligation in ISO-NE, resulting in no enforcement action
•Represented an energy trading company and individual traders regarding FERC's manipulation investigation of relational and loss leader trading involving financial products, physical transactions and virtual trading in the eastern interconnect markets including NYISO, ISO-NE, PJM, MISO and Ontario, resulting in a settlement
•Represented a trading company regarding FERC enforcement's investigation of Lake Erie electricity loop flow causation and impact, resulting in no enforcement action
•Represented energy trading companies and individual traders regarding FERC investigation of manipulation and tariff violation allegations in the western markets and, separately, in the eastern markets, resulting in a closed matters and a settlement
•Represented market systems software developer accused of aiding manipulative conduct before California and U.S. legislative committees, the FERC and California PUC, and California attorney general, resulting in no enforcement action
•Assisted multiple clients with initial inquiries from market monitors, and various FERC divisions and offices regarding natural gas and electricity matters throughout the U.S.
•Assisted a demand response provider regarding enforcement and compliance matters
•Assisted wind generator regarding NERC enforcement matter
•Advised on and conducted compliance audit regarding regulated utility and marketing affiliate FERC standards of conduct (e.g. including cross subsidy, functional separation, transmission and interconnection issues) and NERC rule implementation
•Advise energy companies regarding Dodd-Frank Act (DFA) compliance
•Provide several clients with “root cause” analyses and internal audit services
•Established compliance regimes and evaluation metrics for scores of energy companies, including on-going energy trading and scheduling advisory services
•Revised natural gas marketers sales and energy asset management operations to ensure FERC compliance, including with Order 712
•Advise energy marketer regarding Texas anti-fraud and anti-manipulation rules

Federal and State Regulatory Matters

•Advised energy company regarding capacity supply obligations in ISO-NE
•Advise energy marketers regarding market design and policy issues involving day-ahead and real-time energy, up-to congestion, virtual, and FTR equivalents transactions, including fundamental and quantitative trading
•Advise energy companies regarding DFA swap dealer analysis, on-going business structure, compliance and timelines
•Advise energy companies regarding numerous energy contract DFA issues including swaps and options definitions, embedded optionality, trade options and advisor issues
•Advised generation developer regarding New Jersey and Maryland “contract for difference” long-term capacity rules, agreements and court challenges
•Represented a utility and its marketing affiliate in FERC pipeline wholesale rate and tariff proceeding resulting in successful settlement
•Represented large department store chain as an energy consumer in retail rate, demand response and energy efficiency proceedings before 10 state utility commissions
•Submitted time-sensitive requests for FERC authorization and related waivers to transfer energy assets including contracts and capacity rights on behalf of various banks and funds under the FPA and NGA
•Represented financial institution before FERC regarding ancillary services markets and procurement resulting in a successful settlement
•Represented regulated utility in merger proceeding before the FERC
•Advised multiple trading companies regarding PJM, ISO-NE, CAISO, MISO, IESO and NYISO and retail market design and rules
•Advised wind and geothermal developers regarding interconnection and transmission requirements in MISO, NYISO and other regions
•Reviewed multiple state public utility status rules for rooftop solar developers
•Advised traders and developers regarding state RPS and REC documentation, trading, and tracking rules throughout the United States
•Develop regulatory strategy for cross-border Canadian LNG project
•Counseled clients regarding matters before more than 20 state utility commissions

Transactional and Project Development Matters

•Lead regulatory counsel advising trading entity's $3.5 billion acquisition of a bank's global commodity business
•Lead regulatory counsel on acquisition of natural gas trading business
•Represented energy trading company in the potential acquisition of the book of trades and transactions of another trading entity
•Develop trading, financing and wholesale power supply documentation and regulatory licensing for two retail marketers
•Represented renewable power developer regarding regulatory issues in sale of 100 MW biomass facility located in Texas
•Represented a bank subsidiary regarding regulatory matters in its formation of a strategic alliance with a national solar project developer
•Represented banks regarding standard offer/default/basic generation service procurements (e.g., auctions), supply contracts and credit support in 11 states
•Represented a wind developer regarding regulatory issues associated with a secured financial hedge as part of the financing of wind facilities
•Negotiated multiple PPAs and REC agreements for multiple facilities and buyers utilizing various master and homegrown formats and credit support methods
•Conducted large scale due diligence and advised investor/developer regarding interconnection and transmission rights, including issues of site control and queue position, regarding wind projects in the west/mid-west
•Developed municipal cooperative generation project structures and documentation
•Negotiated generation operation and maintenance, lease, and development agreements for power plant projects
•Analyzed the restructuring and acquisition of debt and equity in 10 distressed generation companies throughout the United States
•Represented large department store chain as an energy consumer regarding solar and wind PPA and REC agreements (Also at Washington, DC Office)


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2014 FERC Enforcement Report Emphasizes Internal Compliance Procedures, Self-Reporting, and Importance of Cooperation
Doron F. Ezickson,Gregory Kusel,Gregory K. Lawrence,Christopher J. Polito, December 10, 2014
The Federal Energy Regulatory Commission’s (FERC) Office of Enforcement (Enforcement) 2014 Report on Enforcement (Report), issued on November 20, 2014, provides an overview of and statistics regarding FERC’s enforcement activities during the fiscal year 2014 within Enforcement’s...

The Fate of FERC Demand Response Order No. 745: Efforts to Adapt While the Judicial and Complaint Processes Play Out
Sohair A. Aguirre,Terence T. Healey,Gregory K. Lawrence,Lamiya Rahman, December 5, 2014
Since our last update regarding the D.C. Circuit’s vacatur of FERC Order No. 745 in Electric Power Supply Ass’n v. FERC ( “EPSA”), several developments have occurred in EPSA and related proceedings. The appeals process and related complaints at FERC will take time to play...

Clear Rift Highlighted by Commissioners’ Lack of Action on New England’s Most Recent Forward Capacity Auction Results
Terence T. Healey,Kenneth W. Irvin,Gregory K. Lawrence,Thomas Reid Millar, October 22, 2014
On September 16, 2014, the Federal Energy Regulatory Commission’s four Commissioners issued statements explaining a 2-2 deadlock between Chairman LaFleur and Commissioner Moeller on the one hand and Commissioner Clark and new Commissioner Bay on the other, over whether to accept rates...

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Gregory K. Lawrence

New YorkNY 10281-0006


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