People

Ryan C. Norfolk - Baker Botts Washington, D.C.
Ryan C. Norfolk
Special Counsel

Overview

Ryan Norfolk advises clients in complex, high-stakes energy regulatory matters at both the state and federal level, focusing on contested regulatory proceedings and enforcement matters before the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the Department of Energy (DOE), and state public utility commissions including the Public Utilities Commission of Ohio, the Minnesota Public Utilities Commission, and the Public Utility Commission of Texas.

Ryan advises electric utilities, gas utilities, independent power producers, generation (both thermal and renewable) and transmission developers, energy traders and marketers, infrastructure funds, and private equity investors on a panoply of issues arising in both the physical and financial markets for electricity, natural gas, oil, and petroleum products.

Ryan also advises clients in the complex regulatory aspects of structured physical and financial energy transactions, project development transactions, mergers and acquisitions, and wholesale power and natural gas transactions.

Before entering private practice, Ryan clerked for the Honorable H. Peter Young and the Honorable Charlotte J. Hardnett with FERC's Office of Administrative Law Judges and Dispute Resolution. He began his legal career as assistant general counsel and regulatory advisor to an international energy services consultancy group.

Admissions & Affiliations

  • District of Columbia Bar
  • Energy Bar Association
  • J.D., George Washington University Law School 2006
    with honors
  • B.A., Political Science, University of Michigan 2001

Experience

Ryan routinely represents clients in both public and non-public proceedings relating to the following:

  • Agency investigations of rules violations and market misconduct including potential market manipulation arising under FERC’s anti-manipulation rules or the Commodities Exchange Act;
  • Exchange inquiries into market participant conduct including allegations of spoofing and position limits violations;
  • Capacity market formation issues;
  • ISO/RTO membership requirements, market/auction participation requirements and restrictions, and strategy documentation; generator interconnection and queue management issues;
  • Compliance with requirements for FERC market-based rate authorized sellers of electricity (e.g., relational database and change in status requirements, market behavior requirements, record retention);
  • FERC Standards of Conduct requirements;
  • Regulation of the transportation and sale of natural gas including asset management agreements, and compliance with FERC’s shipper-must-have-title rule, and related prohibitions on tying and buy/sell transactions; and
  • Crude and petroleum products pipeline development including preparation of precedent agreements.