Jane E. Rueger
Jane has a wealth of experience advising clients in the electric and natural gas industries. Her expertise in both these critical industries has been honed by significant experience in transactional, litigation and regulatory matters.
Jane's knowledge of natural gas and electric industries and markets helps clients navigate complex transactions. She regularly represents clients in the negotiation of power purchase agreements (conventional and renewable generation), M&A transactions, project financings, interconnection agreements, gas pipeline precedent agreements, asset management agreements and LNG offtake agreements. She also counsels market participants on RTO/ISO market rules around the US and the development of creative strategies to successfully operate within those markets.
Jane is a published thought leader in understanding the shale gas revolution in the US. She advises clients on the development, permitting and regulation of interstate gas pipelines, as well as the federal rules and regulations of interstate pipelines and facilities for the export of LNG and gas from the US.
Jane's experience advising clients on litigation matters includes FERC litigation and settlements that involve electric or gas pipeline rates and RTO/ISO market structures. She also represents clients in non-public investigations into alleged violations under FERC's market manipulation rules, the Federal Power Act (FPA), Natural Gas Act (NGA) and Natural Gas Policy Act (NGPA).
A core strength of her practice is the diverse nature of clients she represents, including electric and gas utilities, financial institutions, large industrial consumers of power, offtakers of renewable power, pipeline developers, energy marketers and other utility service providers.
Kelley School of Business
Representation of Pacific Gas & Electric Company in the negotiation of energy storage services agreements to meet PG&E's energy storage mandates, as well as renewable power purchase agreements to meet PG&E's RPS mandates, in the California electricity markets.
Representation of DTE Midstream Appalachia, LLC with respect to its application for a FERC certificate to construct and operate a natural gas pipeline lateral serving new gas-fired generation in Pennsylvania.
Advised Global Infrastructure Partners with respect to federal regulatory considerations associated with its agreement to acquire Medallion Gathering & Processing, LLC (Medallion), the owner of the largest, privately held crude oil transportation system in the Midland Basin of West Texas, for a cash purchase price of US$1.825 billion plus additional cash consideration that is linked to GIP's realized profits at exit.
Representation of corporate offtakers in the negotiation of power purchase and sale agreements applicable to solar, wind and other renewable resource facilities in markets around the US.
Representation of Occidental Chemical Corporation in a petition for enforcement involving an electric utility's obligation under the US Public Utility Regulatory Policies Act of 1978 to purchase power from Qualifying Facilities (QFs) at the electric utility's avoided cost rate.
Representation of Occidental Chemical Corporation in a pending complaint against the Midcontinent Independent System Operator, Inc. (MISO) with regard to the discriminatory treatment of QFs in the integration of the interconnecting utility into the MISO market.
Representation of Fortis, Inc. with respect to regulatory and other issues associated with its December 2013 agreement to acquire UNS Energy, which owns two regulated electric utilities and one regulated gas utility in Arizona. The total cost of the acquisition is US$4.3 billion. We will assist in obtaining state and federal regulatory approvals.
Representation of The Detroit Edison Company with regard to construction of a 102 MW wind generating facility in Michigan, as regulatory counsel, including preparing regulatory filings, providing regulatory advice regarding deal documents, and drafting and negotiating delegation agreements relating to NERC reliability standards.
Assessment and advice with regard to the FERC jurisdictional status of natural gas pipeline facilities and preparation of Abbreviated Applications for Limited Jurisdiction Certificates pursuant to Section 7(c) of the Natural Gas Act (NGA).
"Energy and Climate Finance Opportunities Within," FT Climate Finance Summit, panel presentation, February 6, 2018
"Market-Based Rates Primer: Lessons from the Trenches," Energy Bar Association, webinar presentation, April 23, 2013
"Signals for US electric storage," Project Finance International, September 25, 2019 (co-author)
"Electric storage: From idea to action," White & Case, May 30, 2019 (co-author)
"Fair Winds for Offshore Wind in the US," Project Finance International, July 25, 2018 (co-author)
"Tax Savings & Regulated Rates: Options for FERC Action," January 31, 2018
"FERC, Energy Industry Responds to DOE Coal, Nuclear Mandate," January 12, 2018
"FERC At 40: A Look Back And Ahead," Law360, June 14, 2017 (co-author)
"Electric Energy Storage: Preparing for the Revolution," White & Case, September 2016 (co-author)
"Power Dynamics: Forces Shaping the Future of Coal in the United States," White & Case, October 2015 (co-author)
"Unlocking Demand for Natural Gas Pipelines," White & Case, April 2014 (co-author)
"Investing in U.S. Pipeline Infrastructure: Could the Proposed Master Limited Partnerships Parity Act Spur New Investment?" Harvard Business Law Review, November 2013 (co-author)