Sarah Tracy’s practice focuses primarily on electric and natural gas proceedings before state and federal entities, including state public utility commissions and state and federal courts. Sarah was part of the core legal team in Central Maine Power Company’s recent rate case and regularly represents a Maine based natural gas local distribution company on various regulatory issues, including an ongoing distribution rate case. Sarah also negotiates and drafts agreements for the purchase of electric energy, capacity and renewable energy credits, as well as long-term contracts for natural gas supply and distribution service.

Before joining Pierce Atwood, Sarah was a staff attorney with the Maine Public Utilities Commission (MPUC) in the Legal and the Electricity and Gas Division. At the MPUC, Sarah served as hearing examiner and presiding officer in various proceedings involving electric and natural gas utilities, including proceedings regarding rate recovery and credit facility approvals. In her role as legal advisor to the Commissioners, Sarah also provided general counsel on legal issues related to state and federal laws and regulations.

Before she joined the MPUC, Sarah was a shareholder in the Energy and Environmental Practice Group at Bernstein Shur in Portland, where she represented renewable energy generators before the MPUC, and in permitting proceedings before the Department of Environmental Protection and the Land Use Regulation Commission. Prior to returning to Maine, Sarah was an attorney in the Litigation Practice Group at Holland & Knight LLP in Boston, Massachusetts. Sarah also clerked for the Honorable Donald G. Alexander of the Maine Supreme Judicial Court.

Honors & Distinctions

  • Recognized by 2017 Chambers USA for Energy & Natural Resources Law
  • Rated AV® by Martindale-Hubbell
  • Named a “Rising Star" by New England Super Lawyers in 2009-2010, and 2014-2015
  • Named an energy and natural resources "Lawyer to Watch” by Chambers USA in 2010

Professional Activities

  • Presenter, Natural Gas: Energy for Maine’s Future Conference (2015)
  • Presenter, Natural Gas: Continued Growth in Maine Conference (2014)

Civic Activities

  • Chair, Freeport Ordinance Committee, 2015-present
  • Steering Committee, Tri-Town Track and Field Project, 2015-present
  • Freeport Town Councilor, March 2013-present
  • Freeport Community Services, White Nights Fundraising Committee, 2004-2013
  • Wolfe’s Neck Farm Foundation Board of Directors, 2004-2010

Practice Areas

Sarah has successfully counseled her clients in major energy regulatory proceedings. Sarah’s most significant matters include:

Representative Experience

  • Representation of 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 (MPUC Docket No. 2013-00168)
  • Ongoing representation of a natural gas LDC in its first distribution rate increase request based upon cost of service ratemaking and involving issues related to prudency of expansion investments and rate design (MPUC Docket No. 2015-00005)
  • Ongoing representation of a natural gas LDC 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)
  • Represented a natural gas LDC in obtaining MPUC approval of the LDC’s first long-term contract for firm upstream transportation capacity that will significantly increase reliability of supply and is expected to result in millions of dollars of annual cost of gas savings to customers (MPUC Docket No. 2015-00063)
  • Representation of a natural gas LDC resulting in the approval of its cost-of-gas reconciliation adjustment (MPUC Docket No. 2014-00185)
  • Ongoing representation of industrial energy consumers in the negotiation of long-term contracts for electricity and natural gas

Representative Experience

  • Ongoing representation of a commercial customer to negotiate a power purchase agreement with solar developer for electricity from a solar project located on the customer’s property
  • Ongoing representation of a wind energy generation facility to negotiate a purchase and sale agreement for renewable energy credits 
  • Ongoing negotiation of natural gas supply and natural gas delivery special rate agreements with the local gas utility on behalf of a large commercial intensive energy user 
  • Ongoing representation of 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
  • Ongoing representation of a large commercial agricultural business regarding the development of a co-generation facility
  • Ongoing representation of a local natural gas utility resulting in the approval of its annual cost-of-gas reconciliation adjustment (MPUC Docket No. 2016-00122)
  • Represented a local natural gas utility in its first distribution rate increase request based upon 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 (MPUC Docket No. 2015-00005)
  • 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 (MPUC Docket No. 2013-00168)
  • 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)
  • 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
  • Assisted a community-based renewable energy facility to obtain a larger long-term contract for the energy output from the facility
  • Advised a retail electricity supplier 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