Overview
Chris Zentz has a wide-ranging electric practice that includes regular involvement in both energy transactions and regulatory proceedings before the Federal Energy Regulatory Commission (FERC), State utility commissions, and Bonneville Power Administration. Chris enjoys working with a wide-ranging client base that reflects all sectors of the energy industry, including investor-owned utilities, public power entities, independent power producers, renewable developers, investors, governmental entities, and power marketers.
Chris applies his business background to counsel clients on transactions, in due diligence, and to successfully obtain any necessary authorizations under Section 203 of the Federal Power Act. His experience includes renewable resource development along with the negotiation of transactions involving power, transmission, and storage resources. His transactional experience also extends to obtaining market-based rate authorizations from FERC and in counseling clients on compliance with the Federal statutes such as the Public Utility Regulatory Policies Act (PURPA) and Public Utility Holding Company Act (PUHCA).
Chris’ regulatory practice focuses on assisting clients with various types of Federal regulatory compliance issues, including transmission and ancillary service rate cases, Open Access Transmission Tariff (OATT) implementation and compliance, generator interconnection issues, the FERC Standards of Conduct, interlocking directorate issues, and transmission planning.
Having worked in-house and previously owned his own business, Chris can relate to the pressures, demands, and deadlines his clients face. Drawing on this experience, he brings a practical, solutions-focused approach to timely achieving his clients’ goals. Chris enmeshes himself in his clients’ businesses to better understand the underlying legal needs and goals, thereby allowing him to tailor his legal advice in a way that maximizes the chances of success and achieves his clients’ desired outcome.
- District of Columbia
- Oregon
- J.D., Seattle University School of Law, 2010, cum laude
- B.A., University of Washington, 2007
Representative Matters
Transactional Work
- Represents independent power producers, renewable developers, power marketers, utilities, and investors in power projects in transactional and regulatory matters involving the Federal Power Act, including by obtaining approvals under FPA Section 203 and completing post-closing regulatory obligations.
- Represents purchasers and sellers of energy assets in the negotiation of deal documents, and power purchase and sale, electric storage, transmission service, and interconnection agreements.
- Advises renewable energy developers on various pre-operational matters, including negotiation of interconnection and transmission service agreements, obtaining regulatory approvals and certifications, and resolving disputes over FERC-regulated assets or processes.
- Represented institutional investor in a transaction involving FERC-jurisdictional assets, including in obtaining FERC approvals and post-closing regulatory filings, valued at over $16 billion.
- Represented private equity firm in acquiring FERC-jurisdictional assets, which included negotiation of deal documents, obtaining regulatory approvals, post-closing filings, and ongoing, post-closing FERC compliance obligations.
- Represented two large, institutional investors in renewable generation facilities in obtaining requisite FERC approvals and authorizations to acquire interests in over $2 billion worth of energy assets.
- Counseled a large, independently-owned utility through obtaining FERC approval for two acquisitions of combined cycle gas generation facilities from unaffiliated third parties.
- Experience working with the Western Systems Power Pool Agreement, EEI Master Services Agreement, and custom agreements.
- Represented large public utility in several solar acquisition deals, which included asset purchase agreement negotiation and drafting, preparation of document schedules and ancillary agreements, and oversight of due diligence process.
- Served as project lead on behalf of an international utility and project developer in acquiring a large, pumped storage hydropower generation project, which representation included negotiating and drafting of transaction documents, due diligence, environmental review, and obtaining regulatory approvals.
- Counseled an independently-owned utility on a transaction involving an asset swap and tax deferred exchange of transmission assets and capacity, which included drafting and negotiating documents, obtaining regulatory approvals, drafting ancillary agreements, and researching various, transaction-specific issues.
Regulatory Work
- Represents utilities, renewable developers, and energy companies in various Federal and State regulatory matters involving transactions, rate cases, OATT issues and compliance, negotiation of transmission and interconnection agreements, market-based rates, standards of conduct, interlocking director rules, electronic quarterly reporting, FERC accounting rules, audits, and other compliance matters.
- Represented several utility and developer clients on obtaining various transactional and market-based rate approvals, including approvals under Section 203 of the Federal Power Act, obtaining market-based rate authority, filing of triennial market power updates, and preparing post-transaction regulatory filings.
- Regularly negotiates agreements for transmission service, generator interconnection, transmission-to-transmission interconnection, ancillary services, balancing authority areas, and dynamic transfers.
- Counseled international utility and project developer through all matters for the startup of a new business—namely, formation of an unprecedented generation-only balancing area, which representation included strategic advice on regulatory issues, obtaining regulatory approvals, and advising on compliance matters.
- Represents several of the initial California Independent System Operator Corporation EIM Entities on all stages of start-up and compliance, including drafting regulatory filings and documents; providing advice regarding compliance obligations; preparing OATT revisions, business practice manuals, and other internal compliance manuals; and staying abreast of changes in the EIM market structure.
- Represented a coalition of large, independently-owned utilities throughout the FERC Order No. 1000 Regional Transmission Planning and Cost Allocation compliance process.
- Regularly participates in various state integrated resource plan proceedings on behalf of an international utility and project developer, including drafting and filing comments, reviewing and commenting on various filings, and attending state utility commission proceedings.
- Represented one of the largest, independently-owned utilities on all matters of regulatory compliance before the FERC and various state utility commissions, including in administrative hearings and informal disputes with a federal power marketing agency, and on regulatory compliance issues.
- Advised a large, independently-owned utility on preparation and filing of an ancillary services rate case with FERC to update rate schedules, which included providing assistance and representation throughout the FERC hearing process.
- Represented a large, independently-owned utility in defending a complaint brought by the Bonneville Power Administration before FERC regarding interpretation of the OATT and legacy contracts, rollover rights upon termination of grandfathered transmission agreements, and load service under pre-Order No. 888 agreements.
- Represented a large, independently-owned Northwest utility in connection with a FERC audit and with OATT compliance matters.
News & Publications
Press Releases
Rye Development Selected to Receive $81 Million for Lewis Ridge Pumped Storage Project
March 22, 2024
Client Alerts
FERC's New PURPA Rules Upheld, NEPA Issue Remanded
September 11, 2023
By: Jennifer L. Key, William M. Keyser, Chris D. Zentz, Joe Bower
Media Mentions
Law360 and The National Law Journal Speak to Chris Zentz About Joining Steptoe
August 24, 2023
Press Releases
August 22, 2023
Professional Affiliations
- Oregon State Bar Association (2015 – Present)
- Oregon State Bar Association, Energy, Telecom & Utility Law Section Board (2022 – Present)
- Washington State Bar Association (2010 – Present)