David has successfully handled many investigations, surveillance inquiries, audits, self-reports, internal inquiries, and other compliance matters involving power and natural gas markets. A representative sample of resolved matters includes:

• Represented power trading firm and one of its power traders in a FERC Enforcement investigation into whether their virtual and FTR trading strategy violated FERC's anti-manipulation rule.
• Represented natural gas trader in a FERC Enforcement investigation into whether physical and financial natural gas trades in California violated FERC's anti-manipulation rule.
• Represented an electric utility in a FERC Enforcement investigation into alleged market manipulation and duty of candor violations-referred to FERC by an RTO market monitor-involving the operation of several generation units.
• Represented natural gas pipeline company in FERC Enforcement investigation into compliance with certificate-related Natural Gas Act regulations.
• Represented electric utility in FERC Enforcement investigation into compliance with RTO transmission outage practices.
• Represented electric utility in FERC investigation into compliance with NERC Reliability Standard and FERC Standards of Conduct.
• Represented electric generation company in FERC Enforcement investigation into offers, derating/outage practices, and capacity market compliance in an RTO power market.
• Represented generation companies, utilities, natural gas traders, and natural gas producers in various FERC/NERC electric reliability inquiries.
• Represented a power generation company in a FERC Enforcement investigation into whether the company's offers into an RTO power market were manipulative, anticompetitive, or otherwise violated FERC tariff.
• Represented energy management services company in DAS surveillance inquiry into potentially manipulative physical and financial natural gas trades.
• Represented several electric utilities in FERC audits concerning accounting compliance and NERC Reliability Standards compliance.
• Represented electric utility company in internal investigation into failure to file jurisdictional agreements at FERC, and subsequent self-report to FERC.
• Represented major energy trade associations in preparing and submitting comments opposing FERC's proposed expansion of its Duty of Candor rule.
• Represented major energy trade associations in preparing and submitting to FERC a White Paper on enforcement policy.