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More About Ms. Daly

Education/Degrees
 

  • Notre Dame Law School (J.D.)

  • Notre Dame Law School (Program of International Studies, London, England)

  • University of Notre Dame (B.A., Economics and Business Administration)

Representative Experience
 

  • First chair in natural gas, electric, and oil administrative litigation, certificate and rate proceedings, market-based rate applications, FERC investigations and enforcement actions, rulemakings, and technical conferences.
     

  • Lead negotiator in complex, multiparty settlement proceedings (routinely involving 25-150 parties), drafts, and negotiates consensus documents proposing novel solutions to issues facing the industries.
     

  • Advises clients on issues involving the implementation and compliance with market-based rate authority, Open Access Transmission Tariff (OATT), Open Access Same-Time Information System (OASIS), Standards of Conduct requirements, restrictions on affiliate transactions, FPA Section 203 and 205 applications, requests for interconnections under Public Utility Regulatory Policies Act (PURPA), the calculation of the utilities avoided costs, and various queue related questions.
     

  • Counsels clients on the development and implications of new markets rules and tariff provisions in the various Regional Transmission Organizations (RTOs)/Independent System Operators (ISOs) and represent clients in the public conferences and meetings with FERC representatives.
     

  • Advises clients on UAS issues and programs including registration, operations, special permission/exemption applications, and other best industry practices. Works with clients to establish internal programs (inclusive of policies, processes, and procedures) to demonstrate a culture of compliance and counsels UAS clients on their scope of legal liability. 
     

  • Works directly with general counsels, boards of directors, business leaders, and state and federal regulators and legislators on strategic initiatives, emerging issues, and infrastructure acquisition and development projects (e.g. market area storage, pipeline expansions, solar, wind, LNG, landfill gas and other methane extraction projects, and bridge solutions for data center construction).
     

  • Extensive transactional experience preparing and negotiating all operative contracts relating to the development, construction, interconnection and operation of electric (solar and wind), natural gas, crude, and petroleum products projects, and facilities , including Power Purchase Agreements, Development Agreements, Operating and Balancing Agreements, and Interconnection Agreements.

Awards & Recognition
 

  • The Best Lawyers in America®, Energy Law (2007-2026)

  • Arizona Bar Foundation, Top Pro Bono Attorneys of the Year (2021)

  • Public Utilities Fortnightly, Nation’s Top 25 Regulatory Utility Lawyers (2011) 

  • Martindale-Hubbell®, AV Preeminent® Peer Review Rating (2005-2026)

Representative Experience continued
 

  • Coalition spokesperson and counsel advising industry and regulators on Gas-Electric Coordination issues and the impact of renewable energy on the development of electric and gas markets and the Grid.
     

  • Advises clients on regulatory, contractual, and due diligence matters associated with energy company mergers and acquisitions, construction and operation of electric, natural gas, LNG facilities, oil refineries, and midstream assets for import, export, and domestic uses.
     

  • Conducts corporate in-house Antimarket Manipulation Training and Interstate Commerce Act Compliance programs.
     

  • Responsible for the analytical review and legal preparation of economic, financial, and engineering testimony used to support formula rates, balance sheet analysis, and proposed rate recovery of regulated entities.
     

  • Advises clients on the FAA legal requirements governing Part 107 UAS/drone operations, including airspace authorizations, waivers and issues associated with flights over critical infrastructure.
     

  • Assist clients on the establishment of in-house drone/UAS compliance program and procedures that demonstrate a culture of compliance and incorporate corporate governance, risk mitigation  and operational protocols and structures.
     

Professional Memberships and Activities
 

  • Federation of Defense & Corporate Counsel (2019-Present)

  • Energy Bar Association Officer and Member of the Board of Directors (1996-2001)

  • North American Energy Standards Board Executive Committee (1996-2007)

 

Community Involvement
 

  • Local First Arizona, Board of Directors (2020-2025)

  • Franciscan Renewal Center, Phoenix, Arizona
    Board of Directors (2014-2025)

  • Habitat for Humanity volunteer (2013-Present)

  • Youth basketball volunteer coach (1998-Present)

Education/Degrees

 

  • Notre Dame Law School (J.D.)

  • Notre Dame Law School (Program of International Studies, London, England)

  • University of Notre Dame (B.A., Economics and Business Administration)
     

Awards and Recognition
 

  • The Best Lawyers in America®, Energy Law (2007-2026)

  • Arizona Bar Foundation, Top Pro Bono Attorneys of the Year (2021)

  • Public Utilities Fortnightly, Nation’s Top 25 Regulatory Utility Lawyers (2011) 

  • Martindale-Hubbell®, AV Preeminent® Peer Review Rating (2005-2026)


Representative Experience

 

  • First chair in natural gas, electric, and oil administrative litigation, certificate and rate proceedings, market-based rate applications, FERC investigations and enforcement actions, rulemakings, and technical conferences.

     

  • Lead negotiator in complex, multiparty settlement proceedings (routinely involving 25-150 parties), drafts, and negotiates consensus documents proposing novel solutions to issues facing the industries.

     

  • Advises clients on issues involving the implementation and compliance with market-based rate authority, Open Access Transmission Tariff (OATT), Open Access Same-Time Information System (OASIS), Standards of Conduct requirements, restrictions on affiliate transactions, FPA Section 203 and 205 applications, requests for interconnections under Public Utility Regulatory Policies Act (PURPA), the calculation of the utilities avoided costs, and various queue related questions.

     

  • Counsels clients on the development and implications of new markets rules and tariff provisions in the various Regional Transmission Organizations (RTOs)/Independent System Operators (ISOs) and represent clients in the public conferences and meetings with FERC representatives.

     

  • Advises clients on UAS issues and programs including registration, operations, special permission/exemption applications, and other best industry practices. Works with clients to establish internal programs (inclusive of policies, processes, and procedures) to demonstrate a culture of compliance and counsels UAS clients on their scope of legal liability. 

     

  • Works directly with general counsels, boards of directors, business leaders, and state and federal regulators and legislators on strategic initiatives, emerging issues, and infrastructure acquisition and development projects (e.g. market area storage, pipeline expansions, solar, wind, LNG, landfill gas and other methane extraction projects, and bridge solutions for data center construction).

     

  • Extensive transactional experience preparing and negotiating all operative contracts relating to the development, construction, interconnection and operation of electric (solar and wind), natural gas, crude, and petroleum products projects, and facilities , including Power Purchase Agreements, Development Agreements, Operating and Balancing Agreements, and Interconnection Agreements.
     

  • Coalition spokesperson and counsel advising industry and regulators on Gas-Electric Coordination issues and the impact of renewable energy on the development of electric and gas markets and the Grid.

     

  • Advises clients on regulatory, contractual, and due diligence matters associated with energy company mergers and acquisitions, construction and operation of electric, natural gas, LNG facilities, oil refineries, and midstream assets for import, export, and domestic uses.

     

  • Conducts corporate in-house Antimarket Manipulation Training and Interstate Commerce Act Compliance programs.

     

  • Responsible for the analytical review and legal preparation of economic, financial, and engineering testimony used to support formula rates, balance sheet analysis, and proposed rate recovery of regulated entities.

     

  • Advises clients on the FAA legal requirements governing Part 107 UAS/drone operations, including airspace authorizations, waivers and issues associated with flights over critical infrastructure.


     

  • Assist clients on the establishment of in-house drone/UAS compliance program and procedures that demonstrate a culture of compliance and incorporate corporate governance, risk mitigation  and operational protocols and structures


Professional Memberships and Activities

 

  • Federation of Defense & Corporate Counsel (2019-Present)

  • Energy Bar Association Officer and Member of the Board of Directors (1996-2001)

  • North American Energy Standards Board Executive Committee (1996-2007)


Community Involvement


  • Local First Arizona, Board of Directors (2020-2025)

  • Franciscan Renewal Center, Phoenix, Arizona
Board of Directors (2014-2025)

  • Habitat for Humanity volunteer (2013-Present)

  • Youth basketball volunteer coach (1998-Present)

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