Anna Rachel Biegelsen
Counsel
She/Her/Hers
Washington, D.C.
anna.biegelsen@lw.com
+1.202.637.2191
PRACTICES
- Energy Regulatory & Markets
- Project Development & Finance
INDUSTRIES
- Energy & Infrastructure
EDUCATION
- JD, Harvard Law School, 2012
- BA, St. John's College, 2008
LANGUAGES SPOKEN
PROFILE
Anna Biegelsen advises energy marketing and trading firms, as well as financial institutions that participate in US energy markets, on regulatory, enforcement, compliance, and transactional matters.
Anna helps clients navigate a broad spectrum of Federal Energy Regulatory Commission (FERC) enforcement inquiries and regulatory proceedings relating to:
- Allegations of market manipulation and violations of FERC orders and market rules
- Complaint proceedings
- Market-based rate applications and related proceedings
- Regional transmission organization (RTO) and independent system operator (ISO) tariff amendments
- Acquisition and disposition of FERC-jurisdictional facilities under section 203 of the Federal Power Act (FPA)
- Petition for declaratory order
- Certificiation of Qualifying Facility (QF) and Exempt Wholesale Generator (EWG) status and related issues under the Public Utility Holding Company Act (PUHCA)
Her extensive experience includes successfully resolving several nonpublic investigations, as well as obtaining a FERC decision not to pursue further action against an individual defendant at the order to show cause phase of a market manipulation investigation. She also works with clients to implement compliance programs and develop trainings on the Federal Power Act, the Natural Gas Act, and FERC regulations.
Before joining Latham, Anna advised clients on FERC and Commodity Futures Trading Commission (CFTC) matters at another global law firm.
Anna is a member of the Energy Bar Association.
EXPERIENCE
Anna's experience includes representing:
FERC Enforcement
- A company before FERC in response to allegations by FERC’s Office of Enforcement in connection with capacity auction conduct
- An owner and trader in an FERC enforcement action regarding up-to congestion trading in PJM*
- The senior manager of a generation owner in an FERC enforcement investigation into bidding practices*
- A client in a FERC enforcement investigation into qualification and sales in an ISO-administered capacity auction, which resulted in a favorable finding of no violation*
- A client in a FERC enforcement investigation into adherence to a FERC order*
- A client in a FERC enforcement investigation into another market participant’s financial transmission rights activity and related default*
Energy Regulatory/Compliance
- Drafting a successful petition for declaratory order seeking interpretation of RTO tariff requirements*
- Conducting regulatory due diligence for generation asset acquisitions*
- Preparing successful applications for FERC authorization for mergers and acquisitions under FPA Section 203
- Preparing successful applications for market-based rate authorization under FPA Section 205
- Representing complainants seeking refunds, tariff amendments, or other remedies in FPA section 206 proceedings before FERC*
- Drafting comments on RTO/ISO tariff amendments
- Counseling clients on capacity market design issues and proposed changes*
- Advising a client on FERC Standards of Conduct compliance for transmission providers*
- Reviewing a financial institution’s policies and procedures for regulatory compliance*
- Developing compliance training materials and compliance manuals for a power marketer on FERC, CFTC, and Department of Energy regulations*
- Developing compliance training materials and compliance manuals on FERC Standards of Conduct and FERC/CFTC anti-manipulation regulations*
- Advising clients on petitions for appellate review of FERC orders*
*Matter handled prior to joining Latham