Jennifer L. Key

Jennifer L. Key is of counsel in Steptoe’s Washington office, and focuses her practice on the representation of electric utilities before Federal Energy Regulatory Commission (FERC). She advises these clients in a wide range of transactional matters, administrative litigation, as well as in compliance matters, particularly with regard to open access (Order Nos. 888, 2003, 2006, 890, and 1000), affiliate rules, and FERC filing requirements. She has served as first chair in FERC cases that have proceeded to hearing involving:

Independent System Operator (ISO) transmission service cost allocation
Terms and conditions of transmission owner and wholesale distribution tariffs
Allocation of ISO grid management charges
Classification of facilities installed pursuant to interconnection agreements as transmission or distribution
Qualifying Facilities’ (QFs) responsibility for ancillary service

Ms. Key also focuses on the interplay between state and federal regulation, particularly in light of the increase in distributed generation. Among her successes in this area, Ms. Key successfully represented in obtaining a FERC order that requires that states’ adopting feed-in tariffs abide by the Public Utility Regulatory Policies Act, and she led an appellate effort to reverse FERC orders preempting retail rates for station power service. She also represented a utility in overturning FERC’s attempt to assert exclusive jurisdiction over distribution facilities used for wholesale purposes.

Ms. Key has prepared comments and rehearing petitions for clients in a wide variety of rulemaking proceedings. She also represented the Edison Electric Institute during the North American Energy Standards Board’s development of eTariff. For several years, Ms. Key authored the Annual Electricity Report for the Public Utility, Transportation, and Communications Law Section of the American Bar Association and she continues to contribute to that report.

Ms. Key also provides antitrust counseling and assisted in representing a utility facing a Department of Justice investigation into alleged monopolization.

Good to know

Areas of Practice 1) Energy and 2) Electric Power
Law School The George Washington University Law School (J.D.,1991)
Education Dartmouth College (B.A.,1986)
Bar Member / Association District of Columbia
Most recent firm Steptoe & Johnson
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