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About Blake

Blake Urban advises clients on regulatory matters in the electric industry before federal and state regulatory agencies and appellate courts. He represents clients before the Federal Energy Regulatory Commission (FERC) on matters under the Federal Power Act, Natural Gas Act, Public Utility Holding Company Act and Public Utility Regulatory Policies Act. After law school, Blake worked in the Office of the General Counsel for FERC, where he reviewed and analyzed filings and responsive pleadings submitted under the Federal Power Act, including Sections 205 and 206.

His experience includes obtaining FERC authorization for major projects and transactions, market- and cost-based rate authority for transmission generators, and natural gas storage, reactive power revenue requirements, open access transmission tariff matters, interconnection issues, regional transmission organization (RTO) and independent system operator (ISO) issues, and electric storage resource matters. Blake's practice also includes representing clients on various issues before administrative law judges.

He has represented clients in state electric regulatory proceedings in Florida and California involving complex issues of rate design and policy affecting the industry. In addition, Blake has represented clients in appeals from regulatory agency decisions before the US Court of Appeals for the District of Columbia and Ninth Circuits.


Recent Notable Matters

AP Energy Holdings Inc and South Field Energy LLC — $1.3 billion project financing and equity arrangements for the construction of the South Field Energy project, a 1,182 MW combined-cycle natural gas electric generating facility located near Wellsville, Ohio

GDF SUEZ Energy North America (ENGIE) — representing five of its subsidiaries in reactive power revenue requirement FPA Section 206 proceedings before FERC to determine just and reasonable rates; also assisted client with RTO/ISO registration and compliance

Alcoa Power Generating Inc. — drafting and filing pursuant to FPA Section 205 Open Access Transmission Tariffs, including development of transmission rates

Black Hills Power, Inc. — drafting and implementing transmission formula rate protocols, including annual informational filing

Central Maine Power Company — matters pertaining to FERC

New York State Electric & Gas Corporation — various transmission interconnection issues and service agreements; also advised on matters pertaining to transmission expansion

One of North America's leading energy infrastructure companies — litigation before FERC pertaining to wholesale sales of electricity during the 2000-2001 Western Energy Crisis and, separately, market-based rate authority for natural gas storage service*

* Work completed prior to Bracewell



American University, Washington College of Law,
summa cum laude
The Catholic University of America,
magna cum laude

Bar Admissions

District of Columbia


Intermediate Spanish
Intermediate German


Energy Bar Association
Maryland Bar Association
American Bar Association




FERC Refines DER Wholesale Market Participation Rules

March 24, 2021
Energy Legal Blog®

On March 18, 2021, the Federal Energy Regulatory Commission (“FERC”) issued an order on rehearing of its landmark final rule, Order No. 2222, pertaining to the participation of distributed energy resources (“DER”) through an aggregator in FERC-jurisdictional...

FERC Issues Notice of Inquiry on Possible Expansion of Accounting and Reporting Requirements for Renewable Energy Assets

January 21, 2021
Energy Legal Blog®

On January 19, 2021, the Federal Energy Regulatory Commission (“FERC”) issued a notice of inquiry to explore the treatment of accounting for certain costs associated with renewable energy assets...

FERC Issues Landmark Order on Distributed Energy Resources

September 22, 2020
Energy Legal Blog®

The Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a landmark final rule, Order No. 2222, at its September 17, 2020 open meeting that aims to remove barriers for distributed energy...

FERC Staff Report on High Voltage Transmission Development to Congress

August 18, 2020
Energy Legal Blog®

On Friday, August 7, 2020, Federal Energy Regulatory Commission (“FERC”) Staff sent a report to Congress examining the “barriers and opportunities for high voltage transmission.” FERC Staff prepared this report in accordance with the Congressional directive  contained in...

Electric Transmission and Distribution Utilities and FERC COVID-19 Relief

July 14, 2020
Energy Legal Blog®

On March 13, 2020, President Trump deemed the COVID-19 outbreak in the United States a national emergency as of March 1, 2020. Due to the pandemic, certain electric transmission and distribution public utilities have experienced electricity demand that differs from...

FERC Proposes Significant Reforms to its QF Regulations

September 25, 2019
Energy Legal Blog®

On September 19, 2019, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a Notice of Proposed Rulemaking (“NOPR”) proposing significant changes to FERC’s regulations governing qualifying facilities (“QFs”) pursuant to the Public Utility Regulatory Policies Act of 1978, as amended (“PURPA”)...

FERC Issues Transmission Notices of Inquiry Focused on Return on Equity and Transmission Incentives

March 25, 2019
Energy Legal Blog®

On Thursday, March 21, 2019, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued two Notices of Inquiry (“NOIs”). One NOI focuses on FERC’s approach to determining the Return on Equity (“ROE”) for FERC jurisdictional electric transmission and cost-based wholesale power rates (“ROE Inquiry”)...

FERC Orders Primary Frequency Response Without Compensation

February 28, 2018
Energy Legal Blog®

On February 15, 2018, the Federal Energy Regulatory Commission (“FERC”) revised its regulations to require all newly interconnecting generation facilities to install, maintain, and operate equipment capable of providing primary frequency response as a condition of interconnection...

FERC Eases Barriers for Electric Storage Resources to Participate in Wholesale Markets

February 26, 2018
Energy Legal Blog®

On February 15, 2018, the Federal Energy Regulatory Commission (“FERC”) adopted a final rule (“Order No. 841”) [1] that facilitates the direct participation of electric storage resources in centralized markets operated by Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”)...

Ninth Circuit Affirms Dismissal of Class Action Suit Associated with NERC Reliability Violations

May 23, 2016
Energy Legal Blog®

On March 2, 2016, in an unpublished opinion , the U.S. Court of Appeals for the Ninth Circuit (“Ninth Circuit”) affirmed the judgement of the district court dismissing a class action suit brought by individuals and business entities located within the State of...