Noel Symons co-leads the utility practice of the energy industry team. He represents electric utilities and other energy companies before the Federal Energy Regulatory Commission (FERC) and appellate courts, and also advises on cross-jurisdictional matters involving other regulatory bodies.
Noel’s clients include traditional electric and gas utilities, vertically disaggregated utilities, developers and operators of “merchant” transmission and other forms of nontraditional transmission, merchant generation developers and operators, financial institutions, power marketers, and owners of renewable resources and qualifying facilities.
Noel has extensive experience with Regional Transmission Organization (RTO) tariff and market design, implementation and compliance issues in MISO, SPP and PJM. He is well-versed in the economic and regulatory underpinnings of market design and market operations, the legal and positional dynamics of stakeholder interactions, and the rights and responsibilities of actual or prospective transmission owners, generation owners, aggregators, holders of congestion rights, and load.
Noel frequently counsels clients on interpretation of, and compliance with RTO tariffs and market rules, and acts to advocate rule interpretations in informal communications with RTO personnel. He also works closely with RTO personnel on litigation and other matters where interests are aligned.
Noel counsels clients on policy matters that arise before FERC and assists in the preparation of comments in rulemakings. For example, he represented the Edison Electric Institute in rulemakings on the FERC standards of conduct in both the Order No. 2004 and Order No. 717 rulemaking sequences.
- Representation of a generation owner in a first-of-its-kind complaint proceeding involving whether a regional transmission organization (RTO) should compensate a generator for gas that the RTO directed the generator to purchase, even though the gas was not used to produce power.
- Representation of a utility in obtaining FERC approval for divestiture of its coal-fired generation fleet.
- Representation of a generation owner in taking a leading role for a group of generation owners in a series of high-profile PJM Interconnection LLC (PJM) proceedings involving reform of PJM’s capacity market.
- Representation of a potential investor in analyzing and cataloguing federal, state and RTO requirements for non-incumbent transmission ownership in multiple regions.
- Representation of a utility in taking a leading role for SPP transmission owners in proceedings regarding SPP and MISO Order No. 1000 compliance filings.
- Representation of a utility in successfully defending against a complaint regarding status of its transmission interconnection queue and termination of a transmission lease.
- Representation of a utility in multiple proceedings involving design of MISO’s energy market, and subsequently, its markets for ancillary services and capacity
- Representation of Edison Electric Institute in rulemaking proceedings regarding FERC’s standards of conduct for transmission providers, which resulted in Order No. 2004, Order No. 717, and rehearing orders.
- The Catholic University of America, Columbus School of Law, JD, Faculty Award, Highest Academic Average in the Graduating Class, Member, Catholic University Law Review, 1993
- Carleton College, BA, Political Science/International Relations, Concentration International Political Economy, 1986
- District of Columbia
- U.S. Court of Appeals for the 6th Circuit
- U.S. Court of Appeals for the 7th Circuit
- U.S. Court of Appeals for the District of Columbia Circuit
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