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  • J.D., University of New Hampshire School of Law, 1980
  • B.A., Syracuse University, 1976

Bar Admissions

  • District of Columbia
  • Pennsylvania

Denise C. Goulet

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  • T: 202.753.3439
    F: 202.354.4652
Ms. Goulet has more than 35 years of federal and state energy policy and rate litigation/settlement experience. Representing entities in both the electric and natural gas industries, she focuses on Regional Transmission Organization (RTO) matters, especially those associated with the PJM Interconnection, LLC (PJM), which operates a large competitive wholesale electricity market in the eastern United States. She has represented rural electric cooperatives, municipal utilities, state commissions and state consumer advocate offices on a broad array of matters before the Federal Energy Regulatory Commission (FERC), before similar state regulatory agencies, and in appellate proceedings arising out of those federal and state cases.

Ms. Goulet has extensive experience in counseling clients about RTO markets, electric and natural gas transmission tariffs, rates and pricing, interstate electric transmission planning and cost allocation issues, and issues related to Qualifying Facility interconnections under the Public Utility Regulatory Policies Act of 1978. She has litigated a number of transmission formula rate cases, including the development of formula rate implementation protocols and identification of costs scheduled for recovery under the formula rate. She also has assisted clients with reviews of formula transmission rate annual updates, including litigation of preliminary and formal formula rate challenges. Ms. Goulet also has litigated transmission rate incentive request filings and an affiliate transaction/cross-subsidy complaint, and negotiated favorable settlements in Return on Equity complaint proceedings.

Ms. Goulet’s practice focuses primarily on matters involving organized wholesale electric markets, including capacity market issues in PJM and in ISO New England, and counseling clients about complex market rules related to reliability, competition and pricing. She has been actively involved in most of the proceedings before FERC involving the design of PJM’s capacity market, including recent cases involving capacity performance, buyer and seller side market power mitigation rules, demand curves, cost of new entry, the pricing of reliability-must-run resources, and the role of demand response in capacity markets. Ms. Goulet also has drafted and submitted comments in most major FERC electric policy and rulemaking proceedings over the past ten years on behalf of an ad-hoc coalition of transmission dependent utilities and two national trade associations. She also works on matters relating to state utility rate litigation and state electric and natural gas policy and has advised clients on issues related to the interaction of state and federal policies and rulings. She has litigated or settled numerous electric and gas rate and/or complaint cases before FERC and state public utility commissions and has participated in appeals before the U.S. Court of Appeals for the District of Columbia and Third Circuits.

Prior to entering private practice, Ms. Goulet served for two years as Law Clerk to the Chair of the Public Service Commission of West Virginia, and then for 24 years representing utility consumers, first in West Virginia as Deputy Consumer Advocate, and then in Pennsylvania as Senior Assistant Consumer Advocate. In the latter position, she coordinated all pleadings and rulemaking comments on major electric and natural gas pipeline proceedings before FERC and the appellate courts.

She is a member of Phi Beta Kappa, and was recognized as one of the Groundbreaking Lawyers of 2009 by Public Utilities Fortnightly.

Representative Matters

Annually reviews and litigates transmission formula rate filings, including covering the discovery, preliminary challenge and formal challenge stages.
Successfully challenged PJM’s effort to narrow the Capacity Import Limits exception that would further limit participation by external resources in PJM’s capacity market.
Negotiated favorable settlements in Return on Equity complaint proceedings.
Successfully litigated affiliate cross-subsidy complaint proceeding.
Litigated challenges to a transmission rate incentives filing, including intervening in the appeal to the U.S. Court of Appeals for the Fourth Circuit.


Annual G&T Legal Seminar - National Rural Electric Cooperative Association
Energy Bar Association's 2017 New Orleans Chapter Annual Meeting & Conference