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Kristen Connolly McCullough

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Education

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

Bar Admissions

New York
District of Columbia
United States Court of Appeals for the District of Columbia Circuit
United States Court of Appeals for the 9th Circuit

Honors

Scholar of Law Merit Scholarship Recipient 2002-2005
Dean’s List
Environmental Moot Court advanced to semi-final round
Academic Honor – Congressional & Administrative Law Clinic in DC

Experience

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, Ms. Connolly McCullough 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. In addition, she has handled appeals of FERC cases before the US Court of Appeals for the DC Circuit.

Ms. Connolly McCullough has drafted comments and otherwise been an active participant on behalf of the Firm’s clients in virtually every proceeding regarding the new Electric Reliability Organization (ERO) and mandatory and enforceable Reliability Standards. She has intimate knowledge of the FERC-certified ERO’s, the North American Electric Reliability Corporation (NERC), Rules of Procedure and Compliance Monitoring and Enforcement Program and monitors all actions in the Reliability Standards Development Procedure. 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 Federal Energy Regulatory Commission. These include the development and proposal of new Reliability Standards, Compliance Registry disputes, penalty determinations, ERO/Regional Entity business plan and budget issues, amendments to the Rules of Procedure or ERO/Regional Entity Delegation Agreements, and interpretations of Reliability Standards, 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), undergoing reliability audits and spot checks, and submitting Self Reports and Self Certifications to the appropriate Regional Entity. She regularly attends and monitors workshops and conference calls (held by FERC, NERC and the Regional Entities) to stay at the forefront of reliability issues and proceedings.

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. She ran client meetings; wrote an extensive comment letter to the Missouri Department of Natural Resources opposing the proposed Holcim cement plant; and spoke at a public hearing on behalf of her clients.

Organizations

Energy Bar Association - System Reliability, Planning and Compliance Committee
New York Bar Association
American Bar Association
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