In its Energy Practice, Griggs & Adler, P.C., provides representation before the Federal Energy Regulatory Commission (FERC) in all areas of FERC practice, including oil pipelines, gas pipelines, electric utilities, hydroelectric power, qualified PURPA facilities and independent power producers. Appeals of final FERC orders to United States courts of appeals are part of the Firm's FERC practice. Griggs & Adler typically seeks to obtain lower rates for utility services on behalf of shippers on common carrier pipelines and wholesale consumers of electric power and natural gas.  In its FERC practice, the Firm provides different levels of intervention and participation, tailored to the client's specific needs. Through analysis of the client's particular interests, including the client's budgetary constraints, specific objectives are identified and a strategy to achieve those objectives is developed. Options recommended may range from simple monitoring of FERC developments to full scale intervention in adjudicatory and rulemaking proceedings. Protests of rate filings and active intervention as a party are a common approach. The Firm is prepared to select expert witnesses in the fields of economics, engineering, and ratemaking, or to work with experts selected by the client. The Firm assists in the preparation of direct testimony and prepares the expert witness for cross-examination at hearings. The Firm also drafts discovery requests and responses, handles motions, and drafts prehearing and posthearing briefs.

Less active alternatives are also provided by the Firm. In rulemaking proceedings, comments on proposed rules are drafted and filed with the FERC. Monitoring of developments in proceedings that may be of interest to the client, with provision of periodic reports, is a typical service. This can be supplemented by direct intervention in specific adjudicatory and rulemaking proceedings at the client's specific request. Low profile intervention is an option that allows receipt of all documents served in a case, while avoiding the expense of active participation with live witnesses.

In the oil pipeline field, Griggs & Adler, P. C., has represented shippers on the Trans Alaska Pipeline System (TAPS) and the Williams Pipe Line system, two of the largest and most extensively litigated pipelines. Three separate TAPS Quality Bank cases have been fully litigated over an eighteen year period. The Quality Bank administers a system of payments and credits among TAPS shippers to account for differences in crude oil quality shipped in the pipeline. A trial that spanned nine months in 2002 and 2003 included ten parties and involved over $400 million in Quality Bank charges. Participation in the Quality Bank cases has produced millions of dollars in reductions of Quality Bank payments for the Firm's clients. Another TAPS case, the TAPS Pumpability case, addressed transportation rate design issues and produced lower pipeline rates for the Firm's clients. The Williams case involved a 30-day trial on market power issues under the Buckeye standard. Through participation in this case, Mr. Griggs and Ms. Adler obtained significantly reduced rates for their client. In all of these cases, the Firm achieved the clients' goals while following the budgets set for each project.

In the electric utility field, Mr. Griggs has been lead counsel in cases covering the full spectrum of rate issues, including rate base, rate of return, allocation, rate design, tax issues, transmission rates, and formula rates.  The Firm has achieved substantially lower wholesale rates for its electric utility clients.  Two FERC electric cases in which Mr. Griggs participated included separate antitrust suits that were ultimately settled on terms favorable to his clients. Mr. Griggs has also handled cases at the state commission level involving municipal acquisition of street lighting and electric utility property, as well as rate design and cost allocation issues. The Firm's partners have worked on hydroelectric licensing matters, and Mr. Griggs has written an article about the PURPA incentives for small power cogenerators and independent power producers: "Competitive Bidding and Independent Power Producers: Is Deregulation Coming to the Electric Utility Industry?" 9 Energy Law Journal 415 (1988).

In the gas pipeline field, Mr. Griggs participated in the Order No. 451 case that was reviewed in the Court of Appeals for the Fifth Circuit, and he has participated in FERC hearings involving issues such as minimum bills, take-or-pay provisions and contract carriage for independent marketers of natural gas. In 1986 Mr. Griggs published an article discussing restructuring of the natural gas industry: "Restructuring the Natural Gas Industry: Order No. 436 and Other Regulatory Initiatives," 7 Energy Law Journal 71 (1986).

Efforts now underway include the cutting edge issues of global warming, wind power, and other forms of renewable energy.  Mr. Griggs has been active in reviewing projects associated with coal-fired power plants to demonstrate carbon capture technology, and he is currently involved with the review and assessment of offshore wind projects.  Mr. Griggs recently published an article on the Gulf of Mexico Oil Spill:  "BP Gulf of Mexico Oil Spil," 32 Energy Law Journal 57 (2011).

Mr. Griggs served in the General Counsel's Office of the U.S. Nuclear Regulatory Commission during the late 1970s, where he drafted Commission opinions in licensing matters and participated in litigation brought by a leading environmental group challenging the NRC's decisions on nuclear waste handling, storage and disposal, and uranium mining and milling.

Representative clients for the Energy Practice include Cap Rock Energy Corporation, Chevron Corporation, NewCorp Resources Electric Cooperative, Inc., OXY USA Inc., and Union Oil Company of California.  Former clients represented prior to mergers include Amoco, Conoco, and Unocal.