Bio

Thomas Millar handles a broad array of power and gas transactional and enforcement matters before the Federal Energy Regulatory Commission (FERC) and in federal court, from complex transactions involving FERC-regulated assets to the most sophisticated market manipulation enforcement actions. His experience covers a broad mix of energy regulatory matters, including enforcement defense and energy litigation, as well as the energy regulatory aspects of corporate transactions. With extensive experience practicing before the FERC and federal courts, he is one of just a handful of defense attorneys who has been involved in many of the most significant and highest-dollar power and gas market manipulation cases brought by FERC. The enforcement matters that Tom has handled—brought by FERC, the CFTC, and the DOJ (sometimes jointly)—have total alleged liability nearing US$1B. In addition to his enforcement defense and energy litigation practice, Tom regularly advises on the energy regulatory aspects of significant M&A, private equity, project development, project finance, and other transactions. His focus on regulatory matters also includes electric power and natural gas markets and rates, as well as the representation of energy traders, financial institutions, and electric utilities. He advises clients on the requirements of the U.S. Federal Power Act, the U.S. Natural Gas Act, the U.S. Energy Policy Act of 2005, the U.S. Public Utility Holding Company Act of 2005, the U.S. Public Utility Regulatory Policies Act of 1978, and other federal rules and regulations affecting the energy sector. Tom also advises, and advocates on behalf of, clients with respect to market rules in all restructured energy markets (ISO-NE, NYISO, PJM, MISO, SPP, CAISO, and ERCOT).