Gregory K. Lawrence

Experience: 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.; Represented a financial institution and individuals regarding FERC manipulation investigation of physical and futures trading in the Eastern interconnect, resulting in no enforcement action.; Represented trading company and, separately, demand response provider, in several self-reports regarding trading strategies or asset capacity market registration, each resulting in no enforcement action.; Represented generation owner regarding generation capacity and trading strategy analysis of market power in ERCOT.; 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 marketer's 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.; 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.; 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 closed matters and a settlement.; Represented primary ISO 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.; 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.; 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.; 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.; Advise energy storage and demand response providers regarding energy and capacity market participation in ISO-NE and PJM, including auction strategies and capacity supply obligation management.; Assist retail marketer regarding state utility commission compliance obligations and reporting rules; 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.; 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: Energy regulatory counsel for Puerto Rico Electric Power Authority as it entered financial and regulatory restructuring including advice on PPAs, integrated resource planning, rate setting, microgrids, DERs and regulatory policy as it interrelates with restructuring efforts.; Lead energy regulatory counsel for demand response provider acquisition of another entity.; Lead energy regulatory counsel for financial client purchasing large solar project in terms of FERC FPA 203 and 205 matters and QF, EWG, PUHCA and PURPA analyses.; Lead energy regulatory counsel for an energy trading fund entering into a financial swap and bridge lending related to a developing generation project to meet interconnection milestones.; Lead energy attorney for development group regarding FPA, PURPA and PUCHA legal opinions related to financing and development of several large wind and solar generation projects throughout the United States.; 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.; Lead regulatory counsel preparing an energy asset company for sale including advice regarding diligence, documentation and regulatory requirements.; Regulatory counsel advising Mercuria Energy Group Limited's $3.5 billion acquisition of a bank's global commodity business.; Lead regulatory counsel on acquisition of natural gas trading business.; Represented renewable power developer regarding regulatory issues in sale of 100 MW biomass facilities 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/midwest.; 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.; The above matters were handled by Mr. Lawrence prior to his joining Greenberg Traurig, LLP.; In-House Experience: Counsel, Massachusetts Department of Public Utilities, 1991-1993