Andrea R. Kells Counsel

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Andrea is an energy regulatory attorney who focuses her practice on representing energy and utility clients before the North Carolina Utilities Commission (NCUC) and the Federal Energy Regulatory Commission (FERC).

Before the NCUC, Andrea has a wide range of experience representing major electric and natural gas utilities. In addition to preparing and filing pleadings with the NCUC for these clients across a broad spectrum of matters, Andrea has built significant expertise managing expert witnesses, including preparation of testimony and conducting pre-hearing witness preparation, and managing voluminous discovery, particularly in base rate cases. She has appeared before the NCUC in multiple contested proceedings, including witness presentation, cross-examination, and oral arguments.

Before FERC, Andrea has prepared and submitted filings on behalf of multiple major electric utility companies. She has advised electric and natural gas utility clients regarding compliance with FERC regulations and precedent, and worked with electric utility clients on compliance with NERC Reliability Standards.

Experience

  • Representation of several major North Carolina electric utilities in multiple base rate case proceedings before NCUC.
  • Representation of major North Carolina electric utility in NCUC proceedings regarding state implementation of Public Utility Regulatory Policies Act of 1978 (PURPA), including biennial avoided cost proceedings and arbitration cases involving negotiation of power purchase agreements with qualifying facilities.
  • Representation of major North Carolina electric utility in annual fuel factor adjustment proceedings and other annual riders before NCUC.
  • Representation of major North Carolina electric utility before NCUC in merger proceeding; expertise regarding resulting merger-related conditions and code of conduct compliance, and affiliate transactions.
  • Representation of major North Carolina electric utility before NCUC in proceedings involving state interconnection procedures and integrated resource planning.
  • Advised major North Carolina electric utility client regarding implementation of NC House Bill 589.
  • Representation of North Carolina industrial client before NCUC regarding registration as new renewable energy facility and eligibility to sell Renewable Energy Credits to entities subject to the state’s Renewable Energy and Energy Efficiency Portfolio Standard.
  • Represented multi-state electric utility holding company in proceedings before FERC regarding RTO membership and advised on related issues including compliance with RTO tariffs and FERC precedent.
  • Represented major western electric and natural gas utility before FERC with regard to electric tariff filings, electric rate matters, and advised on impact of natural gas pipeline rate filing on client’s shipper interests.
  • Counseled major East coast electric utility holding companies on compliance with FERC Standards of Conduct and affiliate regulations and compliance with NERC Reliability Standards.
  • Representation of a pro bono client before North Carolina office of the Social Security Administration, Office of Disability Adjudication and Review in case pertaining to alleged overpayment of Social Security Disability benefits.