Sarah B. Tracy
Sarah Tracy is co-chair of Pierce Atwood's energy infrastructure group and advises renewable energy generation facilities, large commercial energy users, and utilities with respect to state and federal energy regulatory issues throughout New England. Notably, Sarah was named in 2025 and 2023 as The Best Lawyers in America® "Lawyer of the Year" in Maine for Energy Regulatory Law.
Sarah assists owners of utility scale and distributed renewable energy generation facilities and off-takers negotiate key energy agreements, including power purchase agreements, net energy billing agreements, renewable energy credit purchase and sale agreements, customer acquisition agreements, natural gas supply agreements and firm gas transportation agreements. She also represents investors and purchasers of energy generation portfolios in conducting state and federal energy regulatory due diligence and advises them on interconnection and ISO-NE issues.
Sarah also represents clients before public utilities commissions in rulemakings and regulatory compliance matters, and assists utilities to obtain approvals for energy infrastructure projects, rate increases, and authorizations to enter into mergers and affiliate transactions.
Prior to joining Pierce Atwood, Sarah was a staff attorney with the Maine Public Utilities Commission (MPUC) in the Legal and the Electricity and Gas Division. This experience provides her with unique insight into the perspectives of energy regulators, which she balances with a deep understanding of the business realities her clients face.
Before she joined the MPUC, Sarah was a shareholder in the Energy and Environmental Practice Group at Bernstein Shur, an attorney in the Litigation Practice Group at Holland & Knight LLP in Boston, Massachusetts, and a law clerk to the Honorable Donald G. Alexander of the Maine Supreme Judicial Court.
Honors & Distinctions
- Named a "Lawyer of the Year" in Maine for Energy Regulatory Law in The Best Lawyers in America® (2023 & 2025)
- Recognized by Chambers USA for Energy & Natural Resources Law (2015-present)
- Recognized by The Best Lawyers in America® for Administrative/Regulatory Law, Energy Law, Energy Regulatory Law, and Utilities Law (2019-present)
- Named a "Lawyer of the Year" in Maine for Administrative / Regulatory Law in The Best Lawyers in America® (2021)
- Rated AV Preeminent® by Martindale-Hubbell
Professional Activities
- Board of Directors, New England - Canada Business Council
- Co-chair, Pierce Atwood Energy Infrastructure Group
- Co-chair, New England Canada Business Council Executive Energy Conference (2022-2024)
- Member, Energy Working Group of the Maine Climate Council (2019-present)
- Program Committee, E2Tech, 2016-present (Program Committee Chair, 2017-2022)
- Board of Directors, E2Tech (2017-present)
Civic Activities
- Board member, Make-A-Wish Maine (2024-present)
- Board member, Freeport High School Scholarship Fund Committee (2022-present)
- Board member, Freeport Economic Development Council (2021–2024)
- Freeport Town Councilor (2013-2020); Town Council Chair (2016-2019); Chair, Freeport Ordinance Committee (2015-2017)
- Steering Committee, Tri-Town Track and Field Project (2015-2019)
- Freeport Community Services, White Nights Fundraising Committee (2004-2013)
- Wolfe’s Neck Farm Foundation Board of Directors (2004-2010)
Practice Areas
Representative Experience
- Assists numerous solar developers, investors, and lenders in conducting due diligence on solar generation assets in Maine and New England for purposes of acquiring, selling, or financing such assets, including evaluation of whether the projects have all appropriate and required federal and state energy regulatory approvals and comply with ISO-NE procedures.
- Ongoing representation of solar developers in negotiation of net energy billing agreements with customers and customer acquisition agreements with channel partners.
- Ongoing representation of large commercial and institutional customers to negotiate net energy billing agreements with solar generation facilities.
- Assists solar developers in interpreting state statutes and regulations regarding net energy billing and distributed generation procurement processes, and developing projects to maximize opportunities under this regulatory framework.
- Ongoing representation of Portland Natural Gas Transmission System, an interstate pipeline utility located in Maine, New Hampshire, and Massachusetts, with respect to MPUC approvals, compliance with state law, and legal advice in connection with operations.
- Represented developer of a biomass combined heat and power (CHP) facility to be located in Maine with project proposal in support of response to Maine Public Utilities Commission request for proposals for CHP projects seeking state-sponsored power purchase agreement.
- Represented a private secondary school in New Hampshire with negotiating a power purchase agreement and long-term lease for the development of a solar energy facility on the school’s property.
- Represented national manufacturer located in Maine to negotiate a virtual power purchase agreement.
- Assisted Central Maine Power Company in obtaining MPUC petition for a Certificate of Public Convenience and Necessity (CPCN) for the 200+ mile New England Clean Energy Connect HVDC transmission line and associated AC upgrades and successfully opposing the appeal of the CPCN at the Maine Law Court.
- Conducted due diligence on behalf of I.W. Holdings Corporation in connection with a significant tax equity investment in a wind farm located in Maine.
- Represented an industrial mill regarding interconnection agreements for its generating facilities, agreements related to demand response services, and advice regarding transmission tariff charges by the local electric utility.
- Represented a local natural gas utility to obtain MPUC approval of the utility’s first long-term contract for firm upstream transportation capacity to significantly increase reliability of supply and generate annual cost of gas savings for customers (MPUC Docket No. 2015-00063).
- Represented a natural gas LDC and an electric T&D utility in a precedent setting proceeding before the MPUC regarding state-sponsored procurement of natural gas capacity for the purpose of lowering electricity prices through the expansion of natural gas pipelines (MPUC Docket No. 2014-00071).
- Assisted a community-based renewable energy facility to obtain a larger long-term contract for the energy output from the facility.
Latest Updates in Energy Infrastructure Project Development & Finance
Representative Experience
- Serving as co-counsel representing Maine’s largest electric utility, Central Maine Power Company (CMP), in an MPUC proceeding to consider a five-year rate plan to build a smarter, stronger, and more resilient grid to serve customers, address the increasing frequency and severity of storms by investing in people, programs, and technology to both limit the damage to its systems and the cost of repair, support Maine’s clean energy transition, and provide predictability in rates (MPUC Docket No. 2025-00218).
- Served as co-counsel representing CMP in an MPUC proceeding that resulted in approval of a multi-year rate plan that funds the utility’s ongoing efforts through rate increases of over $60 million over two years to build a smarter, stronger, more resilient grid for Maine’s clean energy future (MPUC Docket No. 2022-00152).
- Assisted BlackRock, Inc. and its subsidiary First Reserve Energy Infrastructure GP II Limited, to conduct due diligence regarding First Reserve’s acquisition of Gas Natural, Inc., the parent company of Bangor Natural Gas Company (Bangor Gas). Sarah subsequently obtained MPUC approval of the acquisition by negotiating a settlement agreement resolving all issues pertaining to the proposed merger.
- Represented Consolidated Communications Holdings, Inc. in obtaining MPUC approval of Consolidated’s acquisition of FairPoint Communications, Inc. The all-stock transaction was valued at approximately $1.3 billion including debt and based on present equity value.
- Represented a wind energy generation facility in negotiating purchase and sale agreements for renewable energy credits.
- Ongoing negotiation of natural gas supply and natural gas delivery special rate agreements with a local gas utility on behalf of a large commercial intensive energy user.
- Represented a local natural gas utility in its first distribution rate increase request based on cost of service ratemaking, which involved issues related to prudency of expansion investments and rate design. The case resulted in a 34.6% revenue increase in the utility’s largest service territory.
- Represented Maine’s largest electric transmission and distribution (T&D) utility in a rate increase proceeding before the MPUC resulting in a distribution revenue requirement increase of $24.257 million.
- Negotiated a complex long-term electricity supply agreement with major energy supply company involving electricity supply and hedging provisions on behalf of an industrial customer.
- Conducted due diligence regarding energy agreements and regulatory authorizations in the acquisition of retail energy suppliers.
- Assisted industrial customers and generation facilities with state energy regulatory compliance, ISO-NE membership applications, and other regional transmission organization compliance matters.
- Advised retail electricity suppliers regarding regulatory compliance issues for all New England states related to licensure, customer acquisition, and sale of electricity supply business.
- Advised large commercial property owner regarding agreements with condominium associations for water and sewer services.