Jennifer L. Key

Of Counsel

• jkey@steptoe.com
• vCard
• Washington Office

Jennifer L. Key is of counsel with the Washington office of Steptoe & Johnson LLP, where she is a member of the firm's Regulatory & Industry Affairs Department.

Federal Electric Utility Regulation
The primary focus of Ms. Key's practice is the representation of electric utilities before the Federal Energy Regulatory Commission (FERC) in administrative proceedings involving rate schedules, market-based rate authority, rulemakings, and regulatory audits, among other topics.  Ms. Key has served as first chair in FERC cases that proceeded to hearing involving independent system operator (ISO) transmission rates and tariffs, the terms and conditions of transmission owner and wholesale distribution tariffs, and the classification of facilities installed pursuant to interconnection agreements.

Other FERC proceedings she has worked on include issues regarding the allocation of reliability services costs, QF matters, as well as the rates, terms and conditions for transmission service, distribution service, station power service, scheduling and dispatch service, and reactive power service.  Ms. Key regularly assists clients on FERC compliance issues, particularly with regard to the Standards of Conduct, Code of Conduct, and FERC filing requirements, including audits regarding such issues.  She has assisted in drafting transmission tariffs and power sale contracts as well as counseling clients on such matters.  Ms. Key has defended clients against sham wholesale transmission requests, claims of predatory pricing, and allegations of anticompetitive conduct.  Ms. Key also has prepared comments and rehearing petitions for clients in a wide variety of rulemaking proceedings.  For several years, Ms. Key authored the Annual Electricity Report for the Public Utility, Transportation, and Communications Law Section of the American Bar Association and she continues to contribute to that report.

State Electric Utility Regulation
Ms. Key also has experience in the state utility regulatory field and in particular in addressing the interplay between state and federal regulation.  She has assisted clients regarding state-mandated affiliate Codes of Conduct.  Jurisdictional issues relating to transmission and distribution are one of the primary focuses of her state-commission related activities.

Noteworthy

• Electric Power Win; FERC Must Expand Refund Remedy

Professional Affiliations

• American Bar Association, Sections of Public Utility, Transportation, and Communications Law
• Federal Energy Bar Association