Gregory K. Lawrence

Phone202 862 2483

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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: 202 862 2483
Fax: 212 504 6666
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 Releases

• 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

• 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


• 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


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

• 11th Annual Gas and Power Institute Aug 23, 2012

• CTRM Technical Conference 2012 Jul 11, 2012

• Distressed Energy Investments Jun 14, 2012


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


White Collar Defense and Investigations Advisor

• The Dodd-Frank Whistleblower Provisions: Considerations for Effectively Preparing for and Responding to Whistleblowers May 26, 2011

• FinCEN Issues Final Rule on Foreign Bank Account Reporting (FBAR) Mar 01, 2011 (Also at Washington, DC Office)


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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...

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
Terence T. Healey,Kenneth W. Irvin,Gregory K. Lawrence,Thomas Millar, October 6, 2014
On September 17, 2014, the United States Court of Appeals for the District of Columbia Circuit denied the Federal Energy Regulatory Commission’s request for rehearing en banc of the D.C. Circuit’s decision to vacate FERC’s wholesale demand response compensation rule. The D.C....

Gloves Are Off: FERC Issues Public Notice of Alleged Violations in Powhatan Investigation
Terence T. Healey,Gregory K. Lawrence,Christopher J. Polito, August 14, 2014
On August 5, 2014, the Federal Energy Regulatory Commission ("FERC") issued a public Staff Notice of Alleged Violations ("NAV") regarding alleged manipulative Up To Congestion trading by Powhatan Energy Fund (Powhatan) in the PJM energy market. The NAV states that FERC’s...

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Office Information

Gregory K. Lawrence

New YorkNY 10281-0006


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