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Years of Experience
Enforcement Attorney Duties: Responsible for developing the evidentiary record concerning possible violations of North American Electric Reliability Corporation (NERC) Reliability Standards (Standards) by registered entities and providing legal support to the Manager of Enforcement regarding the final disposition of alleged violations. Performs work independently and as a team member. May be assigned to multiple, diverse projects concurrently and in a different capacity as needs dictate. Conducts legal research on applicable NERC precedents and Reliability Standards to ensure appropriate and consistent dispositions of alleged violations, drafts research memoranda, and communicates disposition methods to Texas RE staff and Registered Entities in an effective manner.. Provides support for settlement discussions and assessment of appropriate penalties for confirmed violations.. Develops conclusions and interpretations of relevant NERC Reliability Standards and precedent to support Texas RE management in establishing and articulating compliance enforcement positions.. Analyzes proposed Reliability Standards and supports the Texas RE Standards program in providing comments and voting recommendations in the Standards Development Process.. Reviews and assesses potential noncompliance in accordance with NERC’s Compliance Monitoring and Enforcement Program, including developing the record associated with proposed violations, penalties, sanctions, and reliability recommendations. Drafts discovery regarding noncompliance issues. Drafts formal dispositions pertaining to the enforcement of NERC Reliability Standards, including assessment of risk, the root cause of a possible violation, and appropriate mitigating activities. Monitors active Mitigation Plans and closure of completed Mitigation Plans to ensure noncompliance is corrected in a timely and effective manner. Exercises sound, independent judgment regarding the processing of noncompliance issues. Makes recommendations to the Manager of Enforcement regarding the prioritization and development of noncompliance issues. Drafts violation notices to registered entities concerning assessments. Supports implementation of NERC Rules of Procedure, including Texas RE’s Settlements and Hearing processes in accordance with NERC’s Compliance Monitoring and Enforcement Program. Assists with the drafting of comments regarding proposed NERC Reliability Standards. Provides legal expertise to department members and other Texas RE departments on subject matter or enforcement processes. Provides legal support for settlement negotiations and associated penalty determinations. Prepares drafts of settlement agreements to support Texas RE management. Reviews NERC filings and guidance materials, as well as Federal Energy Regulatory Commission (FERC) orders and provides guidance to Enforcement Staff on legal issues. Provides strategic and/or legal input in resolving noncompliance issues. Assists with the drafting, compilation, and submission of any required compliance filings or oversight materials to NERC or FERC. Ensures that the complete and final record is submitted to NERC. Prepares presentations and communicates program requirements through outreach meetings with interested stakeholders. Represents Texas RE on working groups and committees. Additional duties as assigned.
Qualification and Experience
Requirements: JD Degree from an accredited law school and member in good standing in one or more state bars. 2+ years of relevant legal experience, preferably with demonstrated experience in administrative law, utility regulation, electric utility market regulation, or other equivalent industry experience. Ability to gain comprehensive understanding of the design and limitation of the electric power system through reading of technical reports and reliability standards. Skilled in persuasive writing. Skilled in legal research and writing. Broad overview of the Bulk Electric System and its regulatory environment. General knowledge of corporate issues. Written and verbal communication skills, including presentation skills. Technical comprehension. Organizational skills, including project management skills. Ability to complete tasks in a timely and efficient manner. Analytical skills. Microsoft Word and Excel skills. Preferred: Admitted to practice by the State Bar of Texas. Bachelors’ degree (technical or engineering degree desired) or equivalent industry experience.
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