Michael Keegan has worked on a wide range of energy law issues, with a particular focus on matters before the Federal Energy Regulatory Commission (FERC) and related petitions for review to the courts of appeals. He has advised public utilities, natural gas local distribution companies (including combination electric/natural gas utility companies), state and public entities, and other electric and natural gas market participants.
Mr. Keegan has extensive experience with electric matters at FERC. He counsels public utilities and other electric industry participants regarding bulk sales of electric power at cost-based and market-based rates, transmission open access rules and policies, generator interconnection, merger requirements, affiliate rules, and transactional matters. He has developed contract and tariff provisions for clients, as well as drafted transmittal letters for submission to FERC. He has also reviewed tariff and contract provisions proposed by counterparties and worked with interested parties to achieve mutually agreeable solutions. Mr. Keegan’s experience includes participation in adjudicatory and rulemaking proceedings before FERC, drafting protests and comments filed at the agency.
In the natural gas sector, he has worked with local distribution companies, shippers, and other market participants in contested certificate, rate, and tariff dockets. Mr. Keegan has reviewed interstate pipeline tariff provisions at the request of shippers, to determine whether the provisions are consistent with FERC regulations and policy. He has also advised clients on regulatory compliance issues and assisted in the development of compliance programs and training materials, particularly with respect to FERC’s capacity release program and the shipper-must-have-title requirement.
In addition, he has participated in FERC Enforcement matters, reviewing contracts and other media. He has also drafted memoranda advising energy industry participants regarding statutory and regulatory requirements, as well as FERC precedent and policy.
Prior to joining the firm, Mr. Keegan worked in the energy practice group of an international law firm and as a solo practitioner focusing on energy regulatory issues. Before entering private practice, Mr. Keegan served as a law clerk to the Honorable Carmen H. Alvarez of the New Jersey Superior Court.
Member, Energy Bar Association