Debra D. Roby

Debra D. Roby chairs the firm’s Energy Practice Group and is resident in its Washington, D.C. office. Ms. Roby is a seasoned FERC practitioner, litigator, and negotiator, with over 20 years’ experience representing a variety of stakeholders in the electric industry. She practices before the Federal Energy Regulatory Commission concerning transmission and energy market tariff and rate filings, merger proceedings, rulemakings, hydroelectric licensing and compliance, and other matters. She also assists her clients in negotiations and interactions with other utilities, independent power producers, state utility commissions and Regional Transmission Organizations. She is listed among Washington D.C.’s Super Lawyers in the field of Energy and Natural Resources.

Admitted to Practice

• District of Columbia

Court Admission

• U.S. Court of Appeals, District of Columbia Circuit
• U.S. Court of Appeals, Seventh Circuit
• U.S. Court of Appeals, Eighth Circuit
• U.S. Court of Appeals, Tenth Circuit

• Represents wholesale customers before FERC and related appellate proceedings involving Regional Transmission Organization rates and market design issues
• Represents the Public Utility Commission of Texas before FERC on matters relating to the Midcontinent Independent System Operator and Southwest Power Pool energy market tariffs, transmission development, seams issues, and transmission pricing policies
• Counsels generators and municipal electric systems on RTO interconnection procedures and agreements
• Represents hydro-electric licensees before FERC in licensing and compliance matters, including interfacing with state and federal environmental agencies
• Negotiated and enforced power supply agreements, renewable energy certificate agreements, joint project development agreements, and asset sale agreements
• Counsels municipal utilities regarding compliance with mandatory electric reliability standards, including representation in compliance audits, challenges, and settlement of potential violations
• Represents an entity before a state siting board and state utility commission regarding a proposed transmission route
• Represented several transmission-owning municipal electric utilities seeking to place their transmission assets under the control of a Regional Transmission Organization, including the establishment of an annual transmission revenue requirement and execution of a joint zone revenue distribution agreement
• Represented entities seeking to establish and recover an annual revenue requirement for the provision of reactive support service within a Regional Transmission Organization
• Represented a municipal utility in a complaint action before FERC alleging abuse of market power
• Represented an Affected Unit of Local Government before the Nuclear Regulatory Commission in the High Level Nuclear Waste proceedings

Articles

• Co-author, “In the wake of Hughes v. Talen Energy, might states turn to CHP to help meet future energy demand?” District Energy Magazine (2016)
• Co-author, “Cybersecurity and District Energy Resilience,” District Energy Magazine (2014)

Blogs

• Co-Author, “FERC Terminates Rulemaking Aimed at Increasing RTO/ISO Reliance On Merchant Coal and Nuclear Resources, Initiates New Proceeding to Explore RTO/ISO Resilience Issues,” Jennings Strouss Blog (January 1, 2018)
• Co-author, “The United States Supreme Court Limited the Ability of States to Promote Generation Development,” Jennings Strouss Blog (April 20, 2016)
• Co-author, “The D.C. Circuit Rejects FERC’s Geographical Limitation of Municipal Preference in Hydro Licensing Proceedings,” Jennings Strouss Blog (December 1, 2015)
• Author, “FERC Prepares for Web-Based Filing of Electronic Quarterly Reports,” Jennings Strouss Blog (February 7, 2014)
• Author, “FERC Issues Notice of Proposed Rulemaking for NERC Standard on Geomagnetic Disturbances,” Jennings Strouss Blog (February 7, 2014)
• Co-author, “FERC Confirms That Non-Jurisdictional Contract Rates Are Not Pass-Through Rates Subject To FERC’s Jurisdiction,” Jennings Strouss Blog (August 23, 2013)
• Co-author, “FERC Issues Final Rule Concerning Integration of Variable Energy Resources,” Jennings Strouss Blog (July 2, 2012)
• Co-author, “Changes in NERC Reliability Standards FAC-008/FAC-009 will Take Effect on January 1, 2013,” Jennings Strouss Blog (March 15, 2012)

Presentations

• “Midcontinent Independent System Operator (MISO) & Federal Energy Regulatory Commission (FERC) Update,” MMEA Fall Conference (2019)
• “NERC Reliability Standards, What They Mean for Municipal Utilities,” Kansas Municipal Utilities (2007)
• “An Introduction to EPA’s Coal Ash Rule,” APPA Legal Seminar (2015)

Energy Bar Association

American Public Power Association

District of Columbia Bar Association

• Listed, Washington, D.C. Super Lawyers^® in the category of Energy and Natural Resources (2012 – 2016, 2018 – 2020)