Suzanne P. Keppeler

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Suzanne Keppeler has a wide-ranging electric practice focused on Federal Energy Regulatory Commission (FERC) matters, providing expert advice on rate development; contract, tariff and asset transaction development; regulatory compliance; and investigations support. She also provides strategic advice and counseling on the development of process, procedures, internal training and responses to regulators for North American Electric Reliability Corporation (NERC) and regional reliability standard compliance.

Suzanne has served in a variety of both regulatory policy and legal roles with investor-owned utilities, focusing on FERC matters and NERC compliance. In her in-house corporate roles, she has lead teams developing stated and formula-based transmission rates for electric utilities in bilateral and organized markets, drafting and negotiating unique transmission and interconnection agreements, addressing the day-to-day implementation and interpretation of transmission and market-based rate tariffs, developing internal compliance and training programs, and providing FERC and NERC audit, investigation and enforcement advice. Suzanne has extensive experience advising legal, technical and executive offices on compliance with, and potential violations of, FERC regulations. Suzanne also has served as NERC compliance officer for a mid-sized electric utility and as a regulatory analyst within FERC’s Office of Electric Reliability.

  • Experience

    Electric

    • Advising various public utility clients in developing stated and formula transmission rates and representing clients in rate case proceedings before the FERC.
    • Drafting and negotiating tariff provisions and protocols for public utility transmission systems.
    • Drafting and negotiating transmission and interconnection agreements for public utility clients.
    • Representing various public utilities before the FERC to obtain and maintain the authority to sell electricity at market-based rates.
    • Representing multi-state public utility clients in obtaining federal regulatory approvals of mergers and acquisitions of assets.
    • Successfully litigating complaint proceedings before the FERC on behalf of electric utility clients.
    • Advising various regulated companies on the preparation of internal compliance programs to meet mandatory reliability standards, standards of conduct, affiliate restrictions and open access transmission requirements.
    • Defending and regularly advising regulated companies in audit, investigation and enforcement proceedings regarding market-based rate authority, open access transmission tariff administration, market manipulation and reliability standard compliance.
    • Formerly in-house counsel with: Pinnacle West Capital Corporation (holding company for Arizona Public Service Company); Entergy Corporation (holding company for the 5 Entergy utility companies) and Pepco Holdings, Inc. (holding company of Potomac Electric Power Company, Delmarva Power & Light Company, and Atlantic City Electric Company).

    Natural Gas

    • Representing natural gas pipeline companies in NGA section 7 application proceedings before the FERC.
    • Litigating and negotiating settlements in natural gas rate case and complaint proceedings at the FERC.
    • Providing advice and training on natural gas federal regulatory compliance and jurisdictional matters.

    Oil

    • Representing oil pipelines in ICA ratemaking proceedings.
    • Representing oil pipelines on commercial and regulatory matters for new projects.
  • Professional Affiliations

    American Bar Association

    Infrastructure and Regulated Industries Section

    Energy Bar Association

    Women's Energy Network

  • Awards & Honors
  • Government Service

    Federal Energy Regulatory Commission

    Office of Electric Reliability, Energy Industry Analyst, 2014-2015

    Office of Administrative Litigation, Attorney-Advisor 2000-2001, Energy Industry Analyst, 1998-2000

  • News & Presentations
  • Thought Leadership

Education

Georgetown University Law Center J.D., 1998

Boston University B.A., summa cum laude, 1995