1615 M Street, N.W.
Washington, D.C. 20036
Phone: (202) 467-6370
Fax: (202) 467-6379
Kristen Connolly McCullough
- Washington University in St. Louis School of Law, J.D. 2005
- Brandeis University, B.A. cum laude 2001
- Columbia University, Certificate of Environmental Studies at Biosphere 2 Center, Spring 2000
- New York
- District of Columbia
- United States Court of Appeals for the District of Columbia Circuit
- United States Court of Appeals for the Ninth Circuit
- Supreme Court of the United States
- Scholar of Law Merit Scholarship Recipient 2002-2005
- Dean's List
- Environmental Moot Court Semi-Finalist
- Academic Honor – Congressional & Administrative Law Clinic in DC in the Office of General Counsel at the Federal Energy Regulatory Commission
Ms. Connolly McCullough began at the Firm as a summer associate gaining experience in administrative law and regulatory matters. Since rejoining the Firm as an Associate in 2005, and becoming a Shareholder in 2012, she has worked on electric regulatory matters, environmental issues, as well as oil and gas matters, primarily before the Federal Energy Regulatory Commission (FERC). She has worked extensively on analyzing the FERC’s implementation of the Energy Policy Act of 2005, and in turn, on drafting comments for the Firm’s clients in numerous rulemaking proceedings. She has experience in both state and federal electric and gas rate proceedings. Ms. Connolly McCullough routinely handles the protests and settlement negotiations of the annual rate increases filed at FERC by a large California investor-owned utility on behalf of her clients. In addition, she has handled appeals of FERC cases before the US Court of Appeals for the DC Circuit and Ninth Circuit.
Ms. Connolly McCullough stays at the forefront of reliability issues and proceedings by regularly monitoring and/or drafting pleadings on behalf of the Firm's clients in virtually every proceeding regarding the Electric Reliability Organization (ERO) and mandatory and enforceable Reliability Standards. She has intimate knowledge of the North American Electric Reliability Corporation (NERC), Rules of Procedure and Compliance Monitoring and Enforcement Program and monitors all Reliability Standards development actions taken in accordance with the Standard Processes Manual. She routinely updates clients on developments that affect them whether the action is occurring at the Regional Entity or ERO level, or in a proceeding at the FERC. These include the development and proposal of new and revised Reliability Standards, penalty determinations, amendments to the Rules of Procedure or ERO/Regional Entity Delegation Agreements, interpretations of Reliability Standards, Compliance Registry disputes, and ERO/Regional Entity business plan and budget issues, among others.
She has counseled clients on the development of internal compliance programs and on drafting delegation agreements pertaining to the performance of the Reliability Standards. Ms. Connolly McCullough has also advised clients with respect to navigating their way through the ERO and Regional Entity Compliance Monitoring and Enforcement Programs, e.g., drafting mitigation plans (of potential or alleged Reliability Standards violations), submitting Self Reports and Self Certifications to the appropriate Regional Entity, undergoing reliability audits and spot checks, and drafting responses to Notices of Alleged Violations. She has also negotiated settlements with the relevant Regional Entities, with extensive experience before the Western Electricity Coordinating Council (WECC), on behalf of her clients regarding alleged violations of Reliability Standards and proposed penalties.
Ms. Connolly McCullough also is a former intern with FERC's Office of General Counsel's Markets, Tariffs and Rates Division.
During law school, Ms. Connolly McCullough served as a summer law clerk at the Department of Justice’s Criminal Division in the Eastern District of New York where she worked closely on an environmental crime case regarding a party’s toxic dumping. Later, Ms. Connolly McCullough participated in the Interdisciplinary Environmental Clinic at Washington University in St. Louis where she was the student attorney representing a coalition of environmental groups opposing a proposed cement plant.
- Co-author, The Growing Importance of NERC Reliability Standards to Electric Cooperatives, LEGAL REPORTING SERVICE (Nat'l Rural Elec. Coop. Ass'n, Arlington, Va.), Nov. 2009, at 1.
- Contributing Author, Report of the System Reliability, Planning and Compliance Committee, ENERGY LAW JOURNAL, Volume 30, No. 2 (2009).
- Contributing Author, Reliability Standards Mandated Within Current Energy Markets, in CAPTURING THE POWER OF ELECTRIC RESTRUCTURING 91 (Joey Lee Miranda ed., 2009).
- Panelist, "FERC Update" at the 2009 NRECA G&T Legal Seminar Program in Seattle, WA (Nov. 6, 2009)
- Consultant and Contributor, "What is a Culture of Compliance?" at the Energy Bar Association 2012 Mid-Year Conference in Washington, DC (Nov. 29, 2012)
- Energy Bar Association
- System Reliability and Planning Committee
- Compliance and Enforcement Committee
- Electric Cooperative Bar Association
- New York Bar Association
- American Bar Association
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