eba update - energy bar association · deregulation . when, in the early 80s, then california...

EBA UpdateSummer 2014

www.eba-net.org

President’s Message 2

CFEBA Update 3

Northeast Chapter Update 6

Judge’s Corner 7

EBA Book Club 10

Excerpts from Past ELJ Issues 11

Rocky Mountain Chapter Update 11

YLC Summer Intern Reception 12

Highlights

Presenting Mrs. Smith 15

Upcoming Events 16

®

Founding Editor-in-Chief and pub-lisher of The Energy Daily and De-fense Week, and Creator,Executive Producer and Host ofWhite House Chronicle, among toomany other journalistic and award-winning accomplishments to namehere, Llewellyn King granted amost fascinating interview to newsaficionados Gary Guy and Chan-ning Strother. We have posted anaudio recording of the conversationat http://www.eba-net.org/informa-tion-resources/quarterly-eba-up-date-newsletter/prior-video-interviews. As an extra added attraction,we have also posted at the samelink an award acceptance speechby Mr. King given at the UnitedStates Energy Association 2014Annual Meeting. Both are wellworth listening to, as he had someprofound and provocative things tosay. Here is a brief recap of our in-terview.

King to Regulators:Don’t Deregulate NaturalMonopolies Mr King does not mince words.We asked him about the restructur-

ing of the electric transmissionbusiness. His reaction: it has been“fairly disastrous.” He maintainsthat investors prefer a regulatedcompany such as the SouthernCompany to unregulated utilities,and that the “benefits of deregula-tion haven’t materialized.”

That is not to say that he opposesderegulation per se. When, in theearly 80s, then California PublicUtilities Commission ChairmanJohn Bryson invited him to speakat Stanford on the topic, “Deregu-lating Generating,” he showed upas a deregulation advocate. As hesaw it at the time, it would be agood way to segregate the price ofelectricity rather than mask itthrough the bundling of other costs

Keen Energy Observer LlewellynKing Provides Insights onTackling Industry ProblemsPassionate Advocate for Innovation TellsHow We are Learning the Wrong LessonsGary E. Guy and Channing D. Strother

Llewellyn King

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Well, I’ve made it through the firstfew months of my time as EBApresident and from what I can tellthe organization hasn’t collapsedunder my leadership. The reasonfor that has little to do with me. In-stead, the strength of the organiza-tion lies with the many volunteersand EBA staff who every day workto further the organization’s mission“to promote the professional excel-lence and ethical integrity of itsmembers in the practice, adminis-tration, and development of energylaws, regulations and policies byproviding: superior educational pro-gramming, networking opportuni-ties, and information resources.” Ofcourse, those words mean little un-less there are concrete actions thatmake them a reality. So, in this col-umn, I wanted to point out some ofthe things that the EBA has donerecently to meet its mission, to men-tion some upcoming events, andhighlight one exciting new and easyway for you to support the Charita-ble Foundation of the EBA, at nocost to you.

EBA Primer Series. Under theleadership of past president SusanOlenchuk and our three PrimerDeans, Jonathan Schneider,Jonathan Lesser, and Larry Green-field, EBA is making sure that ourmembers can learn new practiceskills (or refresh old ones) no matterwhere they live and practice. Fol-lowing the success of our first EBAprimer program focused on electric-ity regulation, we held our secondEBA primer program in May inChicago—EBA Gas Primer: An In-troduction to FERC Regulation ofthe Natural Gas Industry. ThePrimer Series is continuing fullspeed ahead. In September, wewill hold our third primer program inBoston—An Introduction to HydroPower Regulation—in conjunctionwith the National Hydropower Asso-

ciation. This program will include avisit to a hydro facility. And, an oiland liquids pipeline program isunder development. So, watch theEBA Primer Series space on theEBA website for more information.

EBA on Demand. EBA has tried itsbest to change with the times tobetter meet our members’ needs. Inan effort to make learning availableto our members at any time, EBA isdeveloping an on-demand library ofprograms. Right now, along withour natural gas regulation primer,we have on-demand programs re-lated to FERC enforcement, smartgrid and demand side resources,mastering your first (or next) statepublic utility commission hearing,and others. Take a look at our OnDemand Program Page to see ourprograms and start to learn on yourown schedule.

EBA’s Efforts Outside the Beltway.EBA’s Chapters are busy as always.The Southern, Northeast, andRocky Mountain Chapters each re-cently held successful annual meet-ings and the Houston Chapter hasa meeting on the calendar on July22nd called Ethical Considerationsin Responding to FERC Investiga-tions. A particularly exciting devel-opment is that the EBA will hold itsfirst meeting in Canada, in Toronto,on September 19th. Keep youreyes open for further informationon that development.

President’s Message Jason F. Leif

ABOUT THE ENERGY BARASSOCIATIONEBA is a non-profit voluntary associa-tion of attorneys, non-attorney profes-sionals and law students whosemission is to enhance the professionalexcellence and ethical integrity of itsmembers in the practice, administra-tion, and development of energy laws,regulations and policies. Established in1946 as the Federal Power Bar Associ-ation, the Association generally was fo-cused on those lawyers practicingenergy regulatory law at the federallevel. In 1977, the organizationchanged its name to the Federal En-ergy Bar Association to reflect thename change of the Federal EnergyRegulatory Commission. Today, theEnergy Bar Association is an interna-tional, non-profit association of attor-neys, non-attorney professionals andlaw students active in all areas of en-ergy law. It has over 2500 members,throughout the United States, Canadaand Internationally with seven formalchapters in Houston, New Orleans,Midwest, Southern, Western; North-east and Rocky Mountain regions ofthe U.S.

Energy Bar Association, 2000 M St.,N.W., Suite 715, Washington, D.C.20036, Tel: 202/223-5625, Fax:202/833-5596, E-mail: [email protected], website: www.eba-net.org

© 2014 Energy Bar Association

®

continued on page 5

2 EBA Update Summer 2014

www.eba-net.org

On the morning of Saturday, April25, 2014, ten EBA members andtheir families joined with 90 othervolunteers along with Casey Treesto plant 70 trees in Langdon Park.Langdon Park is a huge localrecreation facility in the Woodridge-northeast section of Washington,DC, which will also soon be hometo a memorial honoring the famouslate Go-Go singer Chuck Brown.At the outset, the Casey Trees co-ordinator commended CFEBA’sconsistent prior participation insuch events and also recognizedthe financial support that we havegiven. This event also proved to bea great opportunity for CFEBA toprovide service to the community,and it was a first-hand learning ex-perience about tree planting.

Casey Trees provided the volun-teers the appropriate tools, shov-els, hoes, rakes and pics and

divided us into teams of four, whichincluded a more experienced ar-borist. The arborist gave us practi-cal tips about the fine art of treeplanting, like showing us the widthand depth of the ground thatshould be dug-out to ensure stabil-ity and enhance tree growth. Aftereach team planted at least twotrees, the volunteers had a chanceto network and were treated to avariety of scrumptious food selec-tions graciously provided by sev-eral local restaurants in theWoodridge and Brookland sectionsof Washington, DC. EBA membersand friends participating in theCFEBA tree planting event in-cluded, John Calhoun, AdrienneClair, Emma Hand, Fred and Mar-cia Hooks, Jeffrey Janicke, JenniferMoss, Sandi Safro, Delia Pattersonand Yaritza Velez.

The CFEBA will host its 12th An-nual Gala and Silent Auction, LightUp the Night on Tuesday, Novem-ber 4, 2014 in conjunction with theEBA Midyear Conference at theRenaissance Hotel in WashingtonDC. Funds raised at the SilentAuction will be used for energy-re-lated charitable projects, such asproviding medical solar suitcasesto the most needy in the world inan effort to save lives of mothersand children during childbirth invillages where there is no accessto electricity.

Since its inception in 2002, theCFEBA has awarded more than$1,250,000 to deserving nationaland international organizations.EBA members’ participation is nec-essary to ensure a successful gala.To help in this worthwhile en-deavor, members and their employ-ers may contribute in several ways.

Summer 2014 EBA Update 3

Charitable Foundation of the Energy Bar Association UpdateCFEBA Helps to Plant 70 Trees in Langdon Park

Marcia Hooks

CFEBA Annual Gala andSilent Auction

They may provide cash donationsor even sponsor the gala. Theymay also contribute silent auctionitems.

Items the Gala Committee iscurrently requesting:

* Wine

* Kennedy Center, Arena Stageor National Theater tickets etc.

* Gift certificates to restaurants

* Vacation Rentals

On October 6, the State Practiceand Regulation and the YoungLawyer Committees, are planningto host a reception to honor StatePublic Utility Commissioners fromacross the country. Entrance tothe event will be granted in ex-change for a donation of an auc-tion item, hopefully of a valuegreater than $50.

In addition the CFEBA is excitedabout the Gala's fifth annual teamcompetition. The CFEBA encour-ages you to form a team which willdonate an item or basket of itemsto be auctioned. The team thatgenerates the highest winning bidfor the silent auction entry will re-ceive recognition in the EBAnewsletter and bragging rights untilnext year’s silent auction. It's afriendly competition betweenfriends, law firms, and companies,and you have the added satisfac-tion of knowing the proceeds fromyour donation will be used to assistworthy organizations’ energy-re-lated activities. The sky is the limiton what we can achieve workingtogether.

The gala committee is alwaysseeking new volunteers to helpmake the event a success. Please

contact Michele Duehring if inter-ested, or with any gala relatedquestions at 202-223-5625 oremail her at [email protected].

Fundraising Efforts The CFEBA continues to be grate-ful for the strong support it receivesfrom generous members and par-ticularly the giving programs ofmany of the members’ firms. Wecannot overstate the importance ofenergy and the charitable workdone as a result of CFEBA’s grants.Whether it is finding incrementalsolutions for the 20 percent of theworld that has no electric power,finding ways to help the16 percentof Americans who fall below thepoverty line and need help to paytheir utility bills, or helping organi-zations such as Habitat for Human-ity or Meals on Wheels accomplishtheir missions with innovative en-ergy solutions, CFEBA has beenthere, thanks to the generosity ofits members.

We need you to increase yoursupport.

How can we expand both CFEBA’scontribution and the breadth of en-gagement of its membership? Amajor objective that we are reallyemphasizing this year is to get trulybroad participation across all of theEBA, beyond the relatively smallshare of our membership that con-tributes so much. If you have notindividually contributed to theCFEBA (or even if you have),please do so now or at any time.Any amount is welcome; it’s themembership’s individual engage-ment we want to see.

Meanwhile, there is something youcan do right away that can getsome additional funding coming

into the CFEBA, without costingyou anything. All you have to do is:

Register for the AmazonSmile Foundation Please, do this small thing that canmean a lot to us. And, please tellall your family and friends to do thesame.

Whenever you buy from Amazon,go to www.smile.amazon.com andset that as your default when buy-ing from Amazon, designating theCharitable Foundation of the En-ergy Bar Association as your pre-ferred charity.

The Amazon Smile Foundation willdonate 0.5% of the price of each ofyour purchases to the charity youdesignate, the CFEBA.

It doesn't cost the shopper any-thing, and shopping onwww.smile.amazon.com is no dif-ferent than on the regular Amazonwebsite - same products, sameprices, etc., and you use the sameaccount information you normallydo.


CFEBA Update CFEBA Update, continued from page 3

http://smile.amazon.com/ch/01-0743607




EBA’s Midyear Meeting. You willhave seen through our call for top-ics that planning for the EBAMidyear Meeting and Conferenceis well underway under the leader-ship of EBA Program CommitteeChairs Dan Simon, Gary Guy, andMosby Perrow. Mark your calendarfor this event and the CFEBA’s An-nual Gala, which will take place atthe Renaissance Hotel in Washing-ton, D.C. on November 4th to 5th.

Supporting the CFEBA ThroughAmazon Smile. The CFEBA isentering its second decade of giv-ing. While I can go on and on aboutthe CFEBA’s good works, I wantedto do something a little differenthere; highlight an easy, and free,way that you can give to the CFEBAthrough AmazonSmile, a simpleand automatic way to support yourfavorite charitable organizationevery time you shop, at no cost.Full details can be found on page 4,along with registration link. Pleasemake this easy choice and help theCFEBA increase its giving in itssecond decade of good works.

Thanks as always for giving me achance to serve as the EBA presi-dent. If you have any thoughts,comments, or questions, pleasedon’t hesitate to let me know.

related to its transmission and

delivery. But then came the moveto deregulate a natural monopoly,namely, the transmission wiresbusiness. This has caused abreakdown of the public serviceobligation, a franchise contract, asMr. King calls it, all to no good end.There is no longer the sense ofservice in the utility business that“was pervasive” and “the heart-feltpride of public utilities.” Instead, hestates, we have arbitrageurs mak-ing huge profits over a public ne-cessity; we have executives whoare professional money-makersrather than electricity experts. Wewent from a “golden age” beginningwith the Public Utility Holding Com-pany Act of 1935 until we gotderegulation and the “trading ofelectrons,” he tells us. He decriesEnron as having been “out of con-trol” by “starving California of elec-

tricity to up the price.” Regrettably,he said he had three similar enti-ties in mind that are still operatingfor profit motivation without provid-ing corresponding efficiencies. Heis all for free market trading ofproducts that can be stored, butnot for “real time” electricity gener-ation. This new form of transactingsales makes no more sense to Mr.King than if air traffic controllerssold landing slots to pilots calling inbids while in-flight circling runways.

King to Public

Policymakers: Don’tPrevent TechnologicalProgress His antipathy to electric restructur-ing does not mean that Mr. King isopposed to change. Far from it.He believes that technologicalbreakthroughs are being withheldfrom the market out of misplacedfear, wrong-headed politicians, anda false either one extreme or theother environmental debate. Hewarns environmentalists that “evo-lution is the answer,” with bettertechnologies and better under-standing of the sciences. “Morebang for the buck, if you will.”

“Why should nuclear energy be re-garded as something that all left-wing politicians hate and allright-wing politicians love?”, heasks. He calls it a “paradox” thatthere is such a concern with main-taining safety at nuclear powerplants that there is an assumptionthat they must be unsafe ratherthan a recognition that they have,in fact, been made extremely safe.

For example, thanks to the NuclearRegulatory Commission, and itspredecessor, the Atomic EnergyCommission, nuclear power plantsare what he calls the “gold stan-dard” of safety. However, he main-tains that so much has been doneto keep them safe that they arebeing kept from advancing. Hestates that the nuclear industry is“frozen” in light-water fuel rod tech-nology from the late 1960s. Whilegranting that this is still perfectlygood technology, he would like tosee nuclear power produced withrevolutionary new reactors. Hefaults the NRC for insisting that allapplicants adhere to rote, repetitiverequirements rather than take ad-vantage of evolutionary develop-ments.

To illustrate the safety of nuclear


King , continued from page 1

President’s Message, continued frompage 2


The “golden age” ofenergy ended withderegulation and the“trading of electrons”.


EBA Northeast Chapter Update Northeast Chapter Goes Back to NY for Annual Meeting

On June 12, 2014, the Northeast Chapter held its Annual Meeting at the Con Edison Learning Center in New YorkCity. There were four panels: (1) “Resilient Infrastructure: State Initiatives,” which had government officials fromConnecticut, New York, New Jersey and Maryland discussing their most recent storm related initiatives; (2)“RTOs/ISOs Perspectives on Order No. 1000,” which included representatives from the New England, New Yorkand PJM ISOs/RTOs giving their perspectives on the status of Order 1000 implementation; (3) “Restructuring Mar-kets Outside of the US,” which had panelists discussing the current status of restructuring in Great Britain, Canadaand Mexico; and (4) “Exporting Liquefied Natural Gas,” which discussed recent developments in obtaining permis-sion to export natural gas. The meeting was well attended by a wide range of practitioners—public, private, in-house, and firm. The meeting was followed by a networking cocktail party on the roof of a hotel in Long IslandCity that had great views of the Manhattan skyline.

Incoming Chapter President Rick Drom, gives thanks tooutgoing President Rich Miller for his hard work and leader-ship over the 2013-2014 year.

Kate Burson, Chief of Staff to the Chairmanof Energy and Finance for New York, givesthe luncheon keynote at the 2014 NortheastChaoter Annual Meeting.


JUDGE’S CORNER

LUCID LONGHAND FOR LAWYERS: A PERSUASIVE ART

Michael J. Haubner, Administrative Law JudgeFederal Energy Regulatory Commission

Eye no Mai gram her Ann sin tax our write,

Mai spelt Czech tolled mi sew.

Ever wonder why some attorneys’ compositions always seem a bit more persuasive than others’? It’s axiomaticthat a lawyer’s stock in trade is largely comprised of words and their usage. One key to successful legal writing,and admittedly not easy to achieve, is brevity. Cicero once apologized, “If I had more time, I would have written ashorter letter.” If your document looks like it was drafted in the Department of Redundancy Department, it’s timefor a substantial re-write.1 As a judge I generally find repetition in a legal brief to be more tedious than emphatic.I’m not alone in this sentiment. Years ago I heard a respected jurist opine: “The more lawyers write in a case, themore I’m convinced they have nothing to say.”

You should strive to employ the Keep It Simple, or KIS, concept. Make your point, cite supporting precedents andevidence, deal with contrary positions, and get out. Indeed, the Texas Oilman Rule is equally valid in the law: if youdon’t strike pay dirt in ten minutes, stop boring. The seductive argument that “the legal issues in this case are toocomplex for brevity” is often illustrative of a lack of professional application in refining ideas. Cicero’s implication isclear: it takes time and creativity to write concisely. The extra effort, however, could win your case.

1For example, this article was originally 4,592 pages long, but I managed to pare it to its present form in a weekend of editing. Incidentally,

this is as good a place as any to insert the usual lawyer-like disclaimers. Such as, the opinions expressed in this article are my own. My opin-ions do not necessarily reflect the views of the Federal Energy Regulatory Commission or my fellow judges.

continued on page 8

The FERC Practice & AdministrativeLaw Judges Committee proudly pres-ents Federal Energy Regulatory Com-mission Administrative Law JudgeMichael J. Haubner as this issue’s con-tributor to our enlightening “Judge’sCorner” series.

Judge Haubner assumed the FERCbench on January 14, 2013. He previ-ously served as an ALJ at the Office ofDisability Adjudication and Review atthe Social Security Administration, be-ginning in September 1996. Before hisappointment to the bench he was inprivate practice in San Diego, Califor-nia, served as a Superior-Court Arbi-trator, and a Settlement Judge protem.

His Honor’s extensive trial experienceincludes active duty in the UnitedStates Navy Judge Advocate General’sCorps from April 1981 to September

1985. During his last two years in thatcapacity he was assigned as a SpecialAssistant United States Attorney forthe Southern District of California. Healso served as an intelligence officer inthe United States Navy Reserve andwas recalled to active duty duringDesert Storm. Judge Haubner retiredfrom the Reserve in 2003 as a NavyCaptain (the equivalent of a fullColonel). Following his original tour ofduty he was the senior trial associatein a prominent San Diego business-law firm. Thereafter, he served as in-house litigation counsel for a majorindustrial insurer and later ran hisown law firm.

Among Judge Haubner’s impressivescholarly achievements, he has beenan adjunct law professor and is theauthor of over thirty professional arti-cles. For six years he was the Editor-

In-Chief of Dicta Magazine (the SanDiego County Bar Journal). He gradu-ated from The John Marshall LawSchool in Chicago in 1981 and receiveda Bachelor of Science degree cumlaude in Political Science and BusinessManagement from Maryville Univer-sity of St. Louis. He completed the Na-tional Institute of Trial Advocacyprogram on Expert Witnesses and theNational Judicial College’s Civil Medi-ation Training. A friend and active at-tendee at Energy Bar Associationevents, Judge Haubner is licensed inboth California and Illinois.

We are very fortunate to have JudgeHaubner grace these pages with thefollowing excellent insights:


ORGANIZATION

Remember the old law school ex-amination-writing formula known asIRAC (Issue, Rule, Application, andConclusion)? List the Issue, statethe Rule of law, Apply the rule oflaw to the facts, and discuss yourConclusion. As a litigator I founduse of this formula, with one simplemodification, quite persuasive inbrief writing. I called it ISRAC(Issue, Short answer, Rule, Applica-tion, and Conclusion). Followingrecitation of the Issue I added aheading for the Short answer toprovide just that, a succinct indica-tion of my response to the Issue.2

The short answer can and usuallyshould be as concise as stating“yes” or “no.” By giving a short an-swer up front you avoid holding thereaders in suspense or confusingthem. You also reduce the risk oflosing their interest.

Adherence to the Issue, Short an-swer, Rule, Application, and Con-clusion or similar organizationaltool can be useful in preventingrambling text. Long, rambling narra-tives are a common pitfall in draft-ing litigation documents. Suchnarratives can easily fatigue or frus-trate your reader. Thus, it is essen-tial to develop an organizationaloutline and follow it.

BREVITY AND CLARITY

Consistent with understandable,persuasive writing is the use ofshort sentences and paragraphs.Readers can easily get lost indense, lengthy text. This is espe-cially true in energy-litigation briefsinvolving highly technical subjects,such as engineering or accountingprinciples. Breaking up materialwith headings and keeping sen-tence and paragraph lengthsshorter provides white space thatwill help maintain focus.

Most scholars and writers agreethat sentences should generally belimited to around 20 words.3 If yoursentence is longer than that, goback and read it aloud. Try breakingup lengthy sentences by inserting aperiod where you would normallytake a breath.4 Not sure how longyour sentences typically run? Aquick method for determining sen-tence length is to use the word-count function of your wordprocessor.5

To insure your document conveysthoughts clearly, each sentenceshould include only one point oridea.6 Following this rule is vitalwhen the content is technically ori-ented. Multiple ideas in a singlesentence are difficult for a reader toassimilate.

Similarly, paragraphs should in-clude only one topic each.7 Re-garding paragraph length, themajority of writing experts recom-mend limiting each from three toeight sentences.8 Since energylawyers deal with particularly com-plex issues, you should draft shortparagraphs to insure greatercomprehension.9

On occasion, even a single-sen-tence paragraph might be insertedas a transition between points ofan argument.

You should also limit the use ofacronyms, which admittedly can bea challenge in our forum. As onecourt noted:

The electric energy industry hasits own jargon, which makes greatuse of acronyms. With so manyacronyms being used, the testi-mony and briefs become like al-phabet soup where all the lettersswirl around and may confuse thereader.10

While some alphabet soup is prob-ably inevitable in energy litigation,keep in mind that a basic goal ofpersuasive writing is to avoid con-fusion. Restricted use of acronymscan help accomplish that goal.11

Where you must use an acronym,list the entire phrase that forms the

Judge’s Corner, continued from page 7

2 Your phrasing of the issue will be more persuasive if it suggests the answer. For example, “Should the calculations of Witness X be adopted?”isn’t nearly as effective as the following. “If the figures used by Witness X were misapplications of the tariff’s formula, should his calculations bedisregarded?” Obviously, where the judge requests a Joint Statement of Issues you won’t have as much latitude in applying this technique, butbe creative.

3 See e.g., Bryan A. Garner, LEGAL WRITING IN PLAIN ENGLISH 17, 19-21 (University of Chicago Press 2001).

4 By way of illustration, the two sentences you just read were originally written as one long thought. I.e., “If your sentence is longer than that, goback, read it aloud, and try breaking it up by inserting a period where you would normally take a breath.”

5 Using word count a few times can get you in the habit of writing shorter sentences. Sadly, it is fairly common to see energy-law documentscontaining multiple sentences approaching 50 words. I’ve even seen some sentences containing over 100 words. As you might imagine, it isdifficult to digest such a “brief.” Assist your readers; write short sentences.

6 THE PLAIN LANGUAGE ACTION AND INFORMATION NETWORK, FEDERAL PLAIN LANGUAGE GUIDELINES, March 2011, p. 50, avail-able at http://www.plainlanguage.gov/howto/guidelines/FederalPLGuidelines/writeShortSent.cfm (last visited June 18, 2014).

7 Id., p. 62, available at http://www.plainlanguage.gov/howto/guidelines/FederalPLGuidelines/write1Issue.cfm (last visited June 18, 2014).

8 Id., p. 66, available at http://www.plainlanguage.gov/howto/guidelines/FederalPLGuidelines/writeShortPara.cfm (last visited June 18, 2014).

9 Please refer to my standard Rules For Conduct Of The Hearing (Rules For Conduct), §II, ¶20(b), which I issue in all hearing cases. In thoserules I restrict sentence and paragraph length as discussed above.

10 PPL Energyplus LLC v. Hanna, No. 11–745, 2013 WL 5603896 (D.N.J. Oct. 11, 2013).

11 In a recent concurring opinion, Judge Silberman rebuked counsel for liberally using “obscure acronyms, sometimes those made up for a par-ticular case ….” He noted that “the practice constitutes lousy brief writing.” Delaware Riverkeeper Network v. Federal Energy Regulatory Com-mission, No. 13-1015 (D.C. Cir. June 6, 2014). .

continued on page 9

acronym’s basis the first time it ap-pears in a document.12 If a term isused only a few times it’s advisableto recite the full phrase every timeand just omit the acronym. More-over, I find it helpful when counselinclude an appendix of abbrevia-tions and acronyms with eachdocument.13

Clarity is additionally served byavoiding double negatives. Theytoo can be a source of confusion,often forcing the reader to mentallyremove the negatives. Worse yet,double negatives have the poten-tial to create ambiguity that can ob-scure your point. We think in thepositive, so write in the positive.14

BASIC COMPOSITION

At a minimum, grammar, syntax,and word usage errors are distract-ing. They tend to draw the reader’sattention to the faux pas ratherthan the point you’re trying tomake. A few abuses I see fre-quently include: further instead offurthermore at the beginning of asentence15 and into instead of in

to.16 Your word processor’sspellcheck and grammar functionsare convenient tools that should beused. Nonetheless, as illustratedby my farcical example at the be-ginning of this article, it can be follyto rely solely on them. Rather, Ihighly recommend review of agood basic-writing reference, suchas The Elements of Style.17

In addition to being distracting, im-proper sentence construction cancloud or even change the intendedmeaning of your text.18 Considerhow varying the following sen-tence’s syntax alters its meaning.“Their expert was diagnosed by hispsychologist with schizophrenia.”Psychologist jokes aside, a moreapt rendition would be: “Their ex-pert was diagnosed with schizo-phrenia by his psychologist.”Correct application of English-lan-guage fundamentals is, therefore,the first step toward creating luciddocuments.

CONCLUSION

Persuasive legal writing beginswith some basic precepts. Good

grammar, syntax, and usage areessential to conveying yourthoughts clearly. Furthermore, em-ployment of organizational toolsduring the drafting process willmake your job easier and improvesreadability. To facilitate trans-parency provide appendices of ab-breviations and avoid doublenegatives. If you want to maintainyour readers’ attention and con-vince them of your position, keepeach point as rudimentary as pos-sible. Remember, brevity in sen-tence, paragraph, and documentlength is crucial. Best of luck inhoning your writing skills, or as myspellcheck might allow: hears twograte righting!

12 Several energy-industry acronyms are used so frequently by insiders that recognition is naturally assumed. Keep in mind that some readers,such as those at a reviewing court, deal with our terminology less often. Thus, it is prudent to enumerate the basis for every acronym in all doc-uments.

13 Rules For Conduct, supra, §II, ¶20(a). Notwithstanding provision for such an appendix, the more persuasive brief writers simply avoidacronyms.

14 FEDERAL PLAIN LANGUAGE GUIDELINES, supra, p. 54, available at http://www.plainlanguage.gov/howto/guidelines/FederalPLGuidelines/writeNo2Negs.cfm (last visited June 18, 2014).

15 “Further” is usually employed as an adjective that modifies a noun. For the most part, it is not used at the beginning of a sentence (e.g.,“Without further delay.”). It is synonymous with “additional.” “Furthermore” is an adverb that doesn’t modify anything. It is used to support or ex-pand a prior statement. It is generally used at the beginning of a sentence (e.g., “Furthermore, he included pass-through credits.”). It is synony-mous with “in addition.”

16 The word “into” is a preposition that expresses movement or direction. It is roughly synonymous with “against,” “toward,” or “inside” (e.g.,“Kramer walked into the wall when Elaine came into the room”). The two words “in to,” on the other hand, start with “in” as an adverb, followedby the preposition “to.” The phrase “in to” is synonymous with “in order to” (e.g., “Newman came in to say hello.”).

17 William Strunk, Jr. & E.B. White, THE ELEMENTS OF STYLE (Longman, 4th ed. 2000). When I was an adjunct law professor I made thissmall, handy book a required purchase for all my students. It provides fundamental tips and gives examples of improper and proper usage. Un-like the version I used as a student, this edition has an index that helps quickly locate words, phrases, and concepts.

18 For a delightful commentary on punctuation, originally published in England, see Lynne Truss, EATS, SHOOTS AND LEAVES (GothamBooks 2004). The cover depicts a panda painting out the comma after “EATS” while another panda walks away carrying a handgun. Ms.Truss’s book reminded me of a sign I saw as a child along the old Route 66. It read: “EAT AND GET GAS.” Obviously, the sign painter was noteducated by a British punctuation stickler (or nuns with rulers). Admittedly, I was not an English major (although, at one point, I was taught bynuns with rulers). I suspect some sticklers may take issue with my composition or substantive recommendations, or both. Even so, I provide

this perspective to render a glimpse of my writing preferences should I have the pleasure of working with you.

Judge Haubner and his clerk, EvanOxhorn at the 2014 ALJ Reception

Judge’s Corner, continued from page 8


Energy Bar Association Book Club NewsflashPresenting the 3Q, 2014 EBA Book Club

Book of the Quarter:

Keystone XL: Down the Line

By Steven Mufson Reporter, The Washington Post


From the Book Jacket:

The proposed Keystone XL pipelinehas enflamed the bitter fight overAmerica's energy future. Oppo-nents of the 1,700-mile pipeline,which is designed to bring oil ex-tracted from Canadian tar sandsdown to the US, say it represents afurthering of a dead-end oil-basedenergy policy that is unsustainableand poisonous, and have turned thepermit requests to build the pipelineinto an environmental litmus test forPresident Barack Obama. Support-ers of the Keystone XL say it repre-sents a step toward America'senergy independence. Beyond theBeltway, the real story of thispipeline is one about Americanfrontiers - the lengths to which wego for oil and the intrusive effectsthat quest causes all the way downthe line. Steve Mufson, a reporterfor The Washington Post, journeyedby car along the length of the pro-posed pipeline to see what this pol-icy debate looks like at the groundlevel. Each segment of his triptouched on different issues: climatechange and the oil sands; the U.S.energy trade with Canada; theNorth Dakota shale boom and itswoes; prairie populism in Nebraskaand pipeline politics; the Ogallalaaquifer and the threat of leaks; Na-tive Americans and their desire toprotect land, water and burial sitesalong the old Trail of Tears; the fightof ranchers and farmers against aCanadian company’s right to emi-nent domain; and why both oilsands producers and Texas refinerswant to see the pipeline completed.As long as the world relies on fossil

fuels for transportation and industry,we will face unappealing choices.The Keystone XL pipeline serves asa larger metaphor, illuminating thevast energy infrastructure it takes tosustain the American lifestyle andthe debatable choices we mustmake in pursuit of short-term com-fort. Which risks, now and in the fu-ture, are we willing to take?

Note: This book is only availableelectronically. It can be downloadedto your computer, Kindle, smartphone, or other e-reader from Ama-zon.com instantly for $1.99 (if usingAmazon, please remember to signup for Amazon Smile and desig-nate CFEBA as your charity ofchoice!)

Join EBA Book Club: Every EBAMember is invited join for any or allquarterly sessions of the EBA BookClub. Let this be your inspiration toread industry-related literature atyour own pace and discuss, askquestions, share perspectives anddebate the book’s themes and con-clusions with other EBA Members.

The EBA Book Club has both vir-tual and physical platforms to inter-act with other members. Virtually,the EBA Book Club will meet under“Energy Bar Association Book Club”at Goodreads.com. Details follow:

Virtual EBA Book Club:

Please join the online EBA BookClub forum at www.goodreads.com(free registration required). Onceyou create an account, search forand join the Group “Energy Bar As-sociation Book Club.”

EBA Book Club Live:

In honor of the 2Q, 2014 Book TheQuest, the Book Club’s quarterlymeeting will take on a quest of itsown! Please join us the evening ofThursday, August 21st to partici-pate in a Washington, DC UrbanAdventure Quest. We will meet at5:30 pm at Elephant and Castle,located at 1201 Pennsylvania Ave.,NW (important – there are twoE&C’s in DC, so please confirm theaddress), and will embark on thescavenger-hunt style adventure inone or more small groups no laterthan 6:00 pm. We will reconvene atE&C at 8:30 pm to tally scores anddiscuss our quest and The Quest.All are welcome – it is not a prereq-uisite to have finished (or started!)The Quest and/or any prior EBABook Club books.

This event is free of charge, butplease RSVP to [email protected] no later than August19th if you plan to participate.

For more information on the DCUrban Adventure Quest, check out:http://www.urbanadventurequest.com/tours/things-to-do/washington-dc/default.aspx.

Coming Attractions:

Look for the 4Q, 2014 Book of theQuarter in the next edition of EBAUpdate!

Book recommendations are wel-come – please email any sugges-tions to the Book Club Moderator at:[email protected].

Happy reading!


Ten Years Ago“The most effective salve for elec-tricity restructuring would be the re-turn of low natural gas prices andcapacity surpluses. After all, theseare the two factors that created theeconomic conditions that sup-ported the birth of electricity re-structuring in the early 1990s.These factors allowed politicians toembrace deregulatory policy as alow-risk, pro-consumer initiative. Inmany regions, the surplus capacityhas reappeared, but it may take along time for the low natural gasprices to return.”

John S. Moot, Economic Theories ofRegulation and Electricity Restruc-turing, 25 ELJ 273, 318 (2004)

Twenty Years Ago

“In both the natural gas and electricpower industries, the transportationand transmission functions remainmonopolies and need to beregulated in a manner that preventsnatural gas pipeline companies andtransmission-owning utilities fromusing their monopoly positions tofrustrate the benefits that result froma competitive market for natural gasat the wellhead and an increasinglycompetitive market for electricgeneration. Consequently, access tonatural gas transportation andelectric transmission is critical torealizing the potential benefits ofcompetitive markets in natural gasproduction and electric powergeneration. For both industries, theCommission’s policy initiatives havebeen aimed at mitigatingtransportation market power bymeans of requiring open accesstransportation, i.e., the ability of thirdparties to use the transportation owners’system on a nondiscriminatory basis.”

Donald F. Santa, Jr. and Clifford S.Sikora, Open Access and TransitionCosts: Will the Electric IndustryTransition Track the Natural GasIndustry Restructuring?, 15 ELJ 273,294 (1994)

Thirty Years Ago“FERC’s reliance on the first-in-timerule frequently results in the award ofa preliminary permit to an entitywhose plans are not ‘best adapted’but who is merely the applicant whowas able to develop and submit apreliminary permit application first.In most instances, permit applica-tions can be prepared with relativelylittle effort or expense because thetechnical data required by FERCcan be obtained from the Corps ofEngineers. Thus, this rule encour-ages hydroelectric developers tosubmit preliminary permit applica-tions for a large number of sites with-out engaging in the prefeasibilitystudies essential to determinewhether development of a site iseconomically practical. Instead,such studies are routinely performedby developers after a preliminarypermit is issued and the resultingdelay in performing such studieshas led to the surrender of a largenumber of preliminary permits wherethe preliminary permit holder subse-quently determines development ofthe site is infeasible. . . . The FERC’sreliance upon the first-in-time rulethereby permits trigger-happy hy-droelectric developers to tie-up po-tential sites for several years andprecludes actual development byothers.”

Barbara E. Schneider, FERC’s First-in-Time Rule: An Impediment to Hy-dropower Development, 5 ELJ 97,100 (1984) (emphasis in original).

Energy Law Journal: Excerptsfrom Past IssuesAll Prior issues of the Journal are available atwww.FELJ.org

RockyMountainChapter UpdateOn June 20, 2014, the Rocky Moun-tain Chapter held its Second AnnualMeeting at the Xcel Energy officesin Denver, Colorado. The meetingwas one-half day, starting withlunch and ending with a cocktail re-ception. The key energy policy ad-visors from each of the five memberstates, Colorado, Montana, NewMexico, Utah and Wyoming, gavean overview of the key energy is-sues facing each state and howeach is addressing those issues.After a brief networking break, weheard from experts regarding howrecent federal land decisions, thenew EPA water rules, and carbonpollution standards are affecting allaspects of energy development inthe Rocky Mountain Region. Themeeting was well attended by awide range of practitioners—public,private, in-house, firm, electric, oil &gas, and coal. We were also verypleased to have President JasonLeif attend and give supportivecomments. We concluded the busi-ness portion of the afternoon byholding elections for our new offi-cers and Board members.

Thanks again to our Sponsors:

2014 Young Lawyers Summer Intern ReceptionEBA members and guests came together fora lovely reception held by the Young Lawyersin h0nor of the CFEBA and FELJ SummerInterns.


A Special Thank You toOur Sponsors:

PREMIUM SPONSORS

Dentons US LLP

Dorsey & Whitney

Duncan, Weinberg, Genzer & Pem-broke, P.C.

ITC Holdings Corp.

Troutman Sanders LLP

White & Case LLP

Sponsors

Akin, Gump, Strauss, Hauer & Feld,L.L.P.

Day Pitney

Iberdrola USA

McGuireWoods LLP

Stinson Leonard Street LLP

Sutherland

Van Ness Feldman, LLP


power production through newtechnology, he holds up the UnitedStates military. He says they wouldhang you in San Francisco Bay ifyou advocated putting a nuclearpower plant there. Yet, he positsthat a Navy ship would be cheeredin San Francisco Harbor with 8 re-actors on board because of thesense of patriotism for the troopsand confidence in their abilities.But he says that a civilian shipwould not be allowed to come intoport with any reactors. He saysthat the military, with 40 years ofresearch into nuclear technology,has state-of-the art small reactorsthat have promise in the commer-cial world if the government wouldallow the transference of thisknowledge into the marketplace forpeaceful purposes. For emphasis,he states that there is a way of“spiking” fuel so that it cannot beused for weapons but can be usedfor producing power. The marketand the government need to worktogether; neither can operate suc-cessfully at cross purposes withthe other, as he sees it.

He would have the nuclear indus-try evolve much like the natural gasindustry has. He maintains thatfracking of shale gas is an “oldidea” that has been around sinceproduction fields first began, butthat experimentation with newmethods by George Mitchell withgovernment assistance hasbrought this resource into a newstate of development. He believesthat the same can be done withnuclear power if the regulatorswould get out of the way. He sees

the politicians and extremistsamong the environmentalist groupsas holding back needed progressin energy production via nuclear,coal, and other sources.

King to the Public Square:End the False Dichotomyin Public DebatesThe proponents of wind and solaras nirvana versus the proponentsof coal, nuclear, and gas as thepreferred energy sources is a falsedepiction of the choices facing us,King contends. He has calculatedthat it would take at least 8,000windmills to replace the NewHampshire Seabrook Plant, plus agas-fired plant as back-up for whenthe wind does not blow. He likessolar panel roofs on houses, but isskeptical of the mass productionand installation of solar panels.And he is “very dubious” aboutgrowing a food crop, such as corn,in order to make electricity. He hasbeen briefed by the White Houseon self-generation, known as dis-tributed generation, for both on-siteconsumption and for selling of anyexcess to utilities under mandatoryavoided costs provisions of thePublic Utility Regulatory PoliciesAct of 1978. Cheap, clean electric-ity production is needed to makelife better, to create jobs, grow busi-nesses, and to lessen the costs ofjust about everything. He does notagree that “all of the above” energysources will flourish in the market,but he does believe that the market

-- with government assistance --can ensure that energy productionis plentiful, cheap, safe, and envi-ronmentally friendly.

As to the last topic, he warns thathe “treads lightly” in the climatechange/global warming debate be-

cause of his lack of scientific back-ground. However, intuitively hecannot believe that the emission ofbillions of carbon-made effluentsand coal into the air by man-madeproducts over the decades is hav-ing no impact on the detectablemelting of ice caps and increasedacidity of oceans. He believes thatthere are knee-jerk reactionsagainst this view when, for exam-ple, the Heartland Institute con-demns a global warming report byreleasing a press release minutesafter the report is issued withouthaving had the time to even readthe report.

By the same token, he believes theopposition to the Keystone XLPipeline is doing great harm to theenvironment by forcing the use ofrails to move oil sands output andthereby pollute the air. He believes

Unleash nuclear power withsafe, new technology alreadyemployed by the military.

King, continued from page 1


Take climate change seriouslybut build the KeystonePipeline.


that as wrong as the Canadiansare to engage in oil sands produc-tion and transportation, we need toaccept the practice as a fact of lifeand not force Canada to export itsproduction elsewhere with worseenvironmental impacts globally. Hewould bring the Keystone oil supplyto the Gulf Coast and export it. Thiswould reduce the world oil priceand “be the beginning of decou-pling the global price of oil to natu-ral gas, particularly the LNG price.It would give us a seat at the table”at helping the Europeans deal with“the craziness of the Putin regime.”

As to the sophisticated attack onthe Metcalf Plant in California, Mr.King says that we have been givenan “early warning” and need to acton the information in the disclo-sures of the FERC documents thatmany believe should never havecome to light. He believes utilityexecutives most likely do not col-lectively appreciate the need todeal with refurbishing infrastruc-ture, providing new dimensions ofsecurity, including cyber security,and accommodating themselves tonet metering and local self-gener-ating threats to the utility businessmodel. He says they “have a lot ontheir plate” and he will speak tothem about it at an upcoming Elec-tric Energy Institute meeting in LasVegas.

Growing Up in an Energy-Less WorldWe asked him what got him so im-passioned about energy, and werecaptivated at what we learned.Llewellyn King was a British colo-nial energy inspector’s son bornand raised in Africa. In 1968, hesaw first-hand the subsistence inZambia, then-called northernRhodesia, when people were dig-ging trenches for sewer pipes withno electrically-driven machinery,only picks, shovels, and hammersto place platforms 20 feet deep or

more. This was “massive, physicallabor” that he could not do as an18-year-old “in pretty good shape.”He witnessed people cooking dirtymeat in open fires, carrying itemson poles over their back, com-pletely without mechanical equip-ment, without electric lighting, andelectrical means of communication.He recalled hooking a radio to acar battery. He has seen the samesqualor in India before the adventof electricity. He spoke to an In-dian official who told him – cor-rectly – of how everything wouldchange for the better once they ob-tained an electric grid so peoplewill have better hygiene, be able towatch black-and-white TV, and ex-perience a decrease in the birthrate. (“I don’t know if that is be-cause they are watching television

in the critical hours.”) He has seenthe same hand carrying of poles inChina in places where electricity isscarce. He believes that with elec-tricity people achieve the “begin-nings of a better day” and abrighter future, free from want, ill-ness, and poverty. He is soonleaving to go to Turkey and knowsthat he will have good accommo-dations there precisely becauseelectricity has long ago come tothe far-away country. He calls it a“distributive genius” that you cantransport your car anywhere in theworld and fill up the tank with astandardized fuel so that it runswherever you want to drive. Thingswe take for granted are tremen-

Lightening Round withLlewellyn

What he reads: “Better detective stories” He reads them notfor the mystery. Solving the crime is a wayof giving the book a beginning and an end –the “bookends” of the writing. But the “bet-ter” detective story gives you a sense of theculture, history, and people in which the ac-tion takes place. That is its true value. Helikes Canadian crime writer Peter Robinson,and the fictional character CommissarioGuido Brunetti, who solves crimes in aDonna Leon series that takes place inVenice.

Also, history and biography. Recently reada bio of Hugh Trevor-Roper, Lord Dacre ofGlanton, a very eclectic English historian.And he reads a lot of World War I works.He just read Max Hastings book, Catastro-phe 1914: Europe Goes to War. He doesnot like to read about the war; he readsabout the politics of war and the evolution oftechnology since that period. He does notlike to read about weaponry and did not liketo look at the weapons he wrote about inDefense Week. He “shudders at weaponsdesigned to blow up 18 year-olds.”

What he doesn’t read : None of the great tomes on energy regula-tion, nor does he intend to write one. Hekeeps up with energy through the tradepress and the internet (includingOilPrice.com). He has followed the writingsof Amory Lovins, the Rocky Mountain Insti-tute Chairman, physicist, environmental sci-entist, author, and speaker.

Advice to Young People on En-ergy as a Career: “Do not let other people put barriers aroundyou.” Rejection and fear of failure shouldnot deter you from attempting to do newthings. Do not believe that you only havelimited areas where you are talented. Engi-neers tell him they are no good at writingand then give him something to edit that isbeautifully done. A striver will get lots of re-jection, but that leads to success. Do notfear the rejection, and do not rest with lim-ited success. Remember Churchill: “Failureis not fatal; success is not final.”



“It is not a rationalenergy policy tostart with jobs andwork your way backup to a preferredenergy technology.”


dous technological advances thathave improved living standards im-measurably. We inhabit a “cocoonof energy,” as he puts it, with Hous-ton and Miami only inhabited asmajor metropolises because of airconditioning.

He also told us that he loves theenergy field because it “neverstops giving and is so beneficial tomankind.” He sees energy as “partof our freedom” in large part be-cause it allows for mobility ratherthan keeping people living anddying in a 100-mile radius fromwhere they were born. Those thatprovide energy are performing agood in much the same way thatdoctors do, in his view. In addition,to him, the field of energy is “veryseductive,” with its concern withgeopolitics, raw materials, science,imagination, technological innova-tions, economics, and everydaylife. As the world becomes electri-fied, he observes, it becomessmaller and more interconnected.

And he says he sees this fascina-tion with energy among his newscolleagues as well. He has beencovering energy since 1969, whenhe left The Washington Post, to goto McGraw-Hill, started The EnergyDaily in 1973, and sold it in 2006.He has observed that many ofthose who started working for hispublication Defense Week have leftto go to other outlets, including TheNew York Times, Time Magazine,and the Associated Press, where

they cover different subjects. Onthe other hand, the turnover in re-porters who began working for hispublication The Energy Daily hasbeen far less in that they still coverenergy even if they have gone to adifferent publication. He attributesthis interest in covering energy asa shared fixation with him abouthow interesting and important atopic it remains.

Listening to him speak of how hehas lived to see human misery al-leviated with the introduction of anelectric grid, and how he has seena “golden age” followed by bothmisguided regulatory reforms andmisguided thwarting by govern-ment of technological advance-ment, we came away equallyenthralled about this subject. Mr.King sees the need for much moreto be done to right wrongs, solvechallenges, and improve livesthrough energy properly produced,priced, and made accessible. Hiswritings, speaking engagements,interview broadcasts on televisionand radio, all do much to advancethe causes that he advocates inthe energy realm. We are fortunatethat he helps keep the public fo-cused and informed on the energychallenges and opportunities, evenif one may arrive at different con-clusions. Those of us who are in-volved in the energy sectorourselves do well to consider bothhis high praise and his misgivings.

PresentingMrs. Smith For the past ten years, many of youhave gotten to know and workedwith Michele Duehring, EBA Asso-ciate Administrator on CFEBA pro-grams, Chapter events and muchmore. On June 14, 2014, MicheleDuehring married Aaron E. Smith,Jr. in Columbia, MD. EBA sendscongratulations and best wishes toMichele and Aaron!

We are pleased to presentMrs. Michele L. Smith to themembership!


EBA Gas Primer: An Introduction to Hydropower Law andRegulation September 15-16, 2014, JAMS Resolution Center, Boston, MA

Meet Commissioner PickerSeptember 17, 2014, Holland & Knight LLP, San Francisco, CA

EBA's First-Ever Canadian Meeting: EnforcementProceedings before Energy Regulators in Canada and theUnited StatesSeptember 19, 2014, The National Club, Toronto, Ontario

NERC Compliance & Enforcement for PractitionersOctober 2, 2014, GW Law School, Washington, DC

Twelfth Annual Fundraising Gala & Silent AuctionNovember 4, 2014, Renaissance Hotel, Washington, DC

2014 Mid-Year ConferenceNovember 4-5, 2014, Renaissance Hotel, Washington, DC

Check the EBA Calendar for more information on any of these events or ifyou have any quiestions please contact Associate AdministratorMichele L. Smith at 202.223.5625 or [email protected].

Upcoming EBA Events

DIVERSITY POLICY STATEMENT: The Energy Bar Associa-

tion is committed to the goals of fostering an inclusive and

diverse membership and increasing diversity across all lev-

els of the Association, so as to reflect the diversity of the

energy industry and the Nation as a whole. Attorneys, non-

attorney professionals in the energy field and law students

are welcome to join our ranks regardless of race, creed,

color, gender, ethnic origin, religion, sexual preference, age,

or physical disability and are encouraged to become active

participants in the Association’s activities.

The National Hydropower Associa-tion and the Energy Bar Associa-tion are pleased to team togetherto present a primer on the hydro-electric industry. The purpose ofthe primer is to provide attorneyswho are new to the practice of hy-droelectric law a foundational un-derstanding of the hydroelectricindustry and how it is regulated byteaching basic industry fundamen-tals and core regulatory and legalconcepts. The primer also pro-vides an overview of key legal andpolicy issues affecting the industrytoday. Full Program Scheduleand Registration: http://www.eba-net.org/eba-primer-series-introduc-tion-hydropower-law-and-regulation

Optional Plant Tour

Primer Attendees are encouragedto participate in the optional on-sitetour of the Boott HydroelectricProject. There is an additionaltransportation fee of $45 per per-son for the tour. The van will de-part from the JAMS office at 1:30pm and return to the MillenniumBostonian Hotel no later than 6:30pm. Tour participants MUST wearpants and durable close toeshoes. Tour is rain or shine sodress accordingly.

EBAPrimerSeries: An Introduction toHydropower Lawand Regulation September 15-16, 2014

eba update - energy bar association · deregulation . when, in the early 80s, then california...

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