Denise Goulet represents municipal and rural electric cooperative utilities, generators, state regulators, and state consumer advocate offices in federal and state energy matters, including administrative, regulatory, and appellate litigation. She counsels clients on matters involving the organized wholesale electric markets, including capacity market issues in the PJM Interconnection, L.L.C. region, and complex market rules related to reliability, competition, pricing, and market manipulation. She has been involved in most of the proceedings before the Federal Energy Regulatory Commission (FERC) involving the design of PJM’s capacity market, including cases involving capacity performance, fuel security, minimum offer price rule, demand curves, cost of new entry, pricing of reliability-must-run resources, and the role of demand response in capacity markets.
Denise has extensive experience advising on, and defending clients’ interests in, litigation concerning transmission tariffs, transmission and production formula rate implementation and cost recovery schedules, transmission rate incentive requests, transmission planning and cost allocation, and affiliate transaction/cross-subsidy issues. She has negotiated favorable settlements in Return on Equity complaint proceedings and handled issues related to generation and Qualifying Facility interconnections.
Denise has drafted and submitted comments in most major FERC electric policy and rulemaking proceedings over the past ten years for an ad-hoc coalition of transmission-dependent utilities and two national trade associations.
Denise litigates matters relating to state utility rates 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 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 and Fourth Circuits.
In serving her clients, Denise draws from her experience serving in state regulator and public advocate roles. She served for two years as Law Clerk to the Chair of the Public Service Commission of West Virginia, and 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 has been recognized as a Groundbreaking Lawyer by Public Utilities Fortnightly.