Stephen Hug represents clients in matters related to federal and state regulatory policies, regulations and rules applicable to the electric and renewable power industries. He has experience with the Federal Energy Regulatory Commission (FERC) and the Federal Power Act (FPA), including FERC enforcement and compliance, wholesale power trading, centralized energy and capacity markets, transmission and interconnection matters and representation of utilities in contested proceedings before FERC. Stephen also has experience with state regulatory matters, including the Electric Reliability Council of Texas (ERCOT) and Public Utility Commission of Texas (PUCT) regulations, state net metering programs, interconnection issues and retail choice programs.
Prior to joining Bracewell, Stephen was an attorney advisor in the Office of the General Counsel, Energy Markets at FERC, where he reviewed and analyzed filings submitted under Section 205 and 206 of the FPA.
Recent Notable Matters
Equinor — $1.1 billion sale of a 50 percent interest in two US offshore wind development projects to BP, including formation of a partnership to develop and operate the Empire Wind project offshore New York and Beacon Wind project offshore Massachusetts, which together could generate up to 4.4 GW
Texas Microgrid, LLC — first-of-its-kind project financing for the construction and operation of a portfolio of distributed microgrids consisting of ultra-clean natural gas-fired generators within ERCOT service territory with up to 232 MW of generating capacity
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
Publications and Speeches
“NYISO Market Updates & Dynamics: Their Implications for Market Participants,” EUCI, September 2020.
“Another Year of Enforcement at FERC and CFTC,” Law360, January 2017.
“FERC Reconsiders Horizontal Market Power in Transactions,” Law360, September 29, 2016.
“FERC Alters Proposal to Enhance Reporting in Support of Enforcement,” Electric Light & Power, August 2, 2016.
“Court Clarifies Application of FERC Anti-Manipulation Rule to Demand Response Service Providers,” Electric Light & Power, July 19, 2016.
“FERC Denies Request for Discovery by Respondent in FERC Enforcement Case,” Electric Light & Power, May 12, 2016.
“FERC Won’t Penalize Reactive Providers with No Rate Schedule on File but Requires Prospective Filings,” Electric Light & Power, October 28, 2013.
“FERC’s Latest Market Convergence Agenda: Gas and Electric Coordination,” Power Engineering, October 22, 2013.
“FERC Works to Remove Barriers to Transmission Provider, Pipeline Communications,” Electric Light & Power, August 20, 2013.
“High Noon in the 7th Circuit,” Energy & Infrastructure, Energy and Mining Magazine, June 26, 2013.