The Steptoe PURPA and Distributed Energy Resources blog focuses on legal and policy issues raised by distributed energy resources (DERs) (devices interconnected at distribution that can produce or provide energy and other electric services at retail or wholesale) and the Public Utility Regulatory Policies Act (PURPA). On this blog our authors will raise awareness of legal issues that utilities and their state and federal regulators may and should consider as DERs and PURPA “programs” are crafted and adopted, particularly as conflicts can arise between a state and the Federal Energy Regulatory Commission (FERC) regarding matters such as jurisdiction, tariffs, and cost allocation policies.

Jennifer Key is an experienced first-chair lawyer who provides major electric utilities with advice and guidance on the complexities of FERC regulations, and ensures such regulations are adopted and implemented in a manner that is fair and reasonable. Her acute understanding of the intersection of state and federal jurisdiction enables her to successfully shepherd clients through the process of challenging both states and the FERC as necessary, where jurisdictional boundaries are crossed. Jennifer advises her clients in administrative litigation, transactional matters, and compliance matters, particularly with regard to transmission, interconnection, PURPA, wholesale distribution, and FERC filing requirements and orders.


Dave Raskin has more than 35 years of experience representing clients in the electric power industry. He has successfully represented clients in cases involving investigations, mergers and acquisitions, compliance with regulatory rules, generation and transmission project development, industry restructuring, wholesale electric and transmission service pricing, transmission access, wholesale market rules within and outside organized (RTO) markets, contract disputes, antitrust issues, and stranded investment. He has been a lead trial counsel in dozens of FERC proceedings.


Shaun Boedicker focuses his practice on the regulation of electric utilities by FERC. He represents electric utilities in a variety of matters under the Federal Power Act, including Section 205 and Section 206 rate proceedings, Section 203 approvals for mergers and acquisitions, PURPA proceedings, and investigations into utility practices.