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Rebecca Shelton


Washington, D.C.
202 585 6911 202 585 6911 direct

Rebecca represents municipal and cooperative electric utilities in complex electric rate proceedings before FERC.

Rebecca guides clients through the Federal Energy Regulatory Commission (FERC) regulatory landscape, with a focus on electric transmission rate proceedings. She negotiates and litigates on behalf of municipally-owned electric utilities and rural electric cooperatives primarily located in the California Independent System Operator Corporation (CAISO) and Southwest Power Pool (SPP) regions. Drawing on her deep knowledge of FERC regulatory proceedings, Rebecca counsels her clients on cost-based rates, return on equity, formula rates and open access transmission tariffs.

In addition to practicing before FERC, Rebecca monitors and advises clients regarding the North American Electric Reliability Corporation (NERC) Reliability standards development process. Rebecca also guides clients on issues arising under the Federal Power Act and the Public Utility Regulatory Policies Act (PURPA).

Before joining Thompson Coburn, Rebecca served as a law clerk in the Office of Administrative Law Judges at FERC, where she handled electric, natural gas, oil pipeline and enforcement hearing and settlement proceedings.

Representative Matters

Protested and litigated an electric utility's transmission revenue requirement before FERC, including managing expert witness testimony, cross-examining expert and company witnesses and drafting pre- and post-hearing briefs and briefs on and opposing exceptions of the Administrative Law Judge's Initial Decision.

Counseled clients regarding and prepared transmission revenue requirement filings, including both stated and formula rates.

Practiced before the United States Court of Appeals for the D.C. Circuit in petitions for review of FERC orders, including managing the appeals process and preparing briefs.

Litigated a complaint proceeding regarding the return on equity for transmission owners in the Midcontinent Independent System Operator, which involved working with expert witnesses, cross-examination, oral argument and drafting briefs.

Represented intervenors in numerous transmission rate proceedings, including drafting protests and answers, negotiations, preparing settlement documents and writing rehearing requests.

Advised clients regarding market rule changes proposed through the CAISO's Business Practice Manual Change Management Process, including monitoring proposed revisions, drafting comments, preparing appeals and negotiating outcomes with the CAISO staff.


PURPA Policies Then and Now: The Latest Developments for Electric Utilities


“Prepared the 2021 update to the Public Utility Regulatory Policies Act (PURPA) Title II Compliance Manual, for the American Public Power Association, Edison Electric Institute and the National Rural Electric Cooperative Association”;


"How Carbon Pricing Will Affect Your Utility"
American Public Power Association (APPA) Legal & Regulatory Conference, October 2021

"PURPA: The Latest Developments for Electric Utilities"
American Public Power Association (APPA) Legal & Regulatory Conference, October 2017