Sandra Rizzo's practice focuses on energy regulation, litigation, and enforcement. Her clients include electric utilities, power marketers, independent power producers, and investment and hedge funds owning interests in utility assets.
Sandra counsels energy sector clients on regulatory and compliance matters and represents them in enforcement and administrative proceedings before the Federal Energy Regulatory Commission and in litigation in federal courts. She also counsels and represents clients participating in organized wholesale electric markets, including PJM, ISO New England, NYISO, and CAISO, in market rule development, contract disputes, transaction finality, market rule compliance, and capacity market matters.
Her experience includes advising clients on compliance issues, developing comprehensive compliance programs, preparing regulatory filings, and representing clients involved in enforcement proceedings. Additionally, she routinely advocates for the development of and changes to federal regulatory policies, regulations, and rules applicable to the electric industry.
Experience
- PPL Corporation and Talen Energy as counsel on a broad range of regulatory, compliance, and litigation issues over many years. Our work has included playing a major role in the proceedings that led to the development and approval of the PJM Interconnection LLC (PJM) Reliability Pricing Model capacity market construct by the Federal Energy Regulatory Commission (FERC); handling the myriad legal issues in the transaction that led to the formation of Talen Energy; and representation in matters that led to the decisions in Hughes v. Talen Energy Marketing LLC, 136 S.Ct. 1288 and FERC v. EPSA, 136 S.Ct. 760.
- Various defendants in an enforcement matter brought by FERC in federal district court to enforce a judgment of US$42M relating to trading of Up-to Congestion products in the PJM region. Despite the profit opportunity from the trades, and FERC's acknowledgment of the propriety of trades that would not have been made but for a credit paid by PJM, FERC alleges that our clients' trades were inappropriate. While FERC sought to deny us de novo review, the district court agreed that de novo review of the FERC order assessing civil penalties was appropriate. FERC v. Coaltrain Energy, L.P. et al.
- Vistra Energy, Tilton Energy, and Rockland Capital in FERC hearing proceedings in response to our clients' complaints filed at FERC against the Midcontinent Independent System Operator (MISO) alleging mishandling of pseudo-ties between MISO and the neighboring PJM region. We brokered a settlement that, upon implementation, collectively will provide our clients with multi-million dollar refunds.
- RC Cape May, a generator that had planned to deactivate but was needed by PJM for reliability, in assisting with the negotiation and filing of a Reliability Must-Run Agreement, working through thorny issues in the FERC-established settlement process, and assisting in the implementation of the approved agreement.
Perspectives
Recognition
Energy: Regulatory — Conventional Power (2013-2014, 2018-2022)
Energy: Litigation (2008-2012)
Energy: Transactional & Regulatory (2011)
Credentials
Education
- J.D., College of William and Mary Law School
- B.A., The George Washington University
Admissions
- District of Columbia
- Supreme Court of the United States
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Third Circuit
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. District Court, District of Columbia