Energy Regulatory & Commercial Advisory

Advisory for large industrial energy users

Harper Advisory advises large industrial energy consumers across the US on regulatory proceedings, energy procurement, commercial strategy, and renewable energy — with particular focus on organized wholesale markets including ERCOT, CAISO, and PJM.

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Large industrial end users — companies for whom energy is a significant cost of production — bring distinct commercial pressures, operating constraints, and regulatory exposure to every engagement. Harper Advisory was purpose-built for that client, by people who have managed energy at that scale.

Regulatory advocacy before state utility commissions and state agencies including CPUC, PUCT, and CARB
Energy procurement, commercial strategy, and demand response in organized and unorganized markets
Renewable energy and battery storage advisory from feasibility through execution
Industrial facility with solar installation
What We Do

Advisory built around industrial competitiveness

Regulatory

Representation and advocacy in state utility commission proceedings, ISO/RTO stakeholder processes, and state agency matters. Expert witness testimony, formal comments, settlement proceedings, and policy engagement on behalf of large industrial energy consumers.

Rate Cases Expert Testimony CPUC · PUCT ISO/RTO Stakeholder

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Commercial

Energy market strategy and commercial guidance calibrated to the realities of industrial buyers — commodity risk management, energy contract negotiations, demand response participation, and support for new and expanded load interconnections.

Risk Management Contract Negotiation Demand Response Load Interconnection

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Renewables & Storage

Renewable energy and battery storage advisory for industrial buyers: feasibility, Private-Use-Network configuration, behind-the-meter BESS analysis, RFP development and management, and commercial negotiation support through project execution.

PPA Structuring BESS Feasibility RFP Management PUN Configuration

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Sam Harper at ERCOT Board proceedings
ERCOT Board of Directors
Elected annually 2016–2021 to the ERCOT Board, serving through the Winter Storm Uri reliability crisis.
ERCOT Innovation Summit panel
ERCOT Innovation Summit
Active participant in market and industry proceedings, representing large industrial energy consumers.
Representative Experience

The kind of work we do

Commercial & Regulatory
Greenfield Industrial Facility — Load Interconnection & Microgrid

Advising a greenfield industrial facility on load interconnection strategy, tariff development and optimization, and microgrid design to achieve operational targets, minimize delivered energy cost, and meet environmental goals. Scope includes utility engagement, interconnection agreement negotiation, and coordination with state regulatory processes.

CPUC · Stakeholder Representation
CLECA — California Regulatory Representation

Ongoing regulatory representation of the California Large Energy Consumers Association (CLECA) across CPUC proceedings — general rate cases, rate design, demand response, direct access, RPS rulemaking, and CARB proceedings. CLECA members represent steel, cement, industrial gas, and other manufacturing industries with aggregate California demand exceeding 500 MW.

cleca.org ↗ LinkedIn ↗
Renewables & Storage · PJM
Major Steelmaker — Behind-the-Meter BESS Feasibility & Procurement

Advising a major steelmaker on the installation of a behind-the-meter battery energy storage system (BESS) in PJM to lower energy cost and improve operational resilience. Scope includes detailed tariff, market, and operational cost savings analysis; feasibility assessment; RFP process management; and commercial negotiation support.

Commercial & Regulatory · CAISO
California Manufacturer — Major Expansion Planning

Advising a California manufacturer on a major production expansion, including long-term commodity price forecasts customized to the client's interval energy profile and operations pattern to support technology decisions, regulatory treatment of on-site generation and storage resources, and analysis of economic development rate options.

Strategy
Energy Strategy & Roadmap — Load Growth & Decarbonization

Developing an integrated energy strategy and roadmap for a major manufacturer navigating production expansion in an era of load growth and tight supply — covering resource planning, decarbonization goal alignment, and long-term cost predictability across operations.

Renewables · Industrial Buyer
Industrial Manufacturer — Renewable Energy Procurement

Advising a large industrial manufacturer on renewable energy procurement strategy, including evaluation of procurement structures — utility green tariff, direct PPA, and behind-the-meter options — RFP development and management, developer proposal assessment, and commercial negotiation support through contract execution.

Regulatory Intelligence
Demand Response Regulatory Monitoring

Ongoing regulatory monitoring and interpretation for industrial demand response programs — tracking rule changes, tariff updates, and market design modifications across ISO/RTO markets, and advising clients on the operational and commercial implications for their demand response participation and planning.

ERCOT · Stakeholder Representation
ERCOT Steel Mills — Regulatory Representation

Ongoing representation of the ERCOT Steel Mills stakeholder coalition in PUCT proceedings and ERCOT market design matters — commissioner engagement, large load interconnection standards, transmission cost allocation methodology (4CP), and market rule proceedings. The coalition represents electric arc furnace steelmakers operating in the ERCOT market.

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Principal

Sam Harper

Sam Harper, Principal, Harper Advisory LLC

Sam Harper spent fifteen years managing energy at scale for major North American steel producers — first at ArcelorMittal, then at Gerdau — before founding Harper Advisory. That operating experience spans ERCOT, PJM, CAISO, MISO, IESO, CENACE, and various unorganized markets. From 2016 to 2021, Harper served on the ERCOT Board of Directors — a role that brought direct involvement in the Texas market's most consequential regulatory period, including Winter Storm Uri and its aftermath.

Full bio & team Sam Harper on LinkedIn ↗
Public Record

Work you can verify

Regulatory Filings
Selected filings before the CPUC, PUCT, and CARB

Expert witness testimony and formal comments on behalf of large industrial energy consumers — each with a plain-English summary of the proceeding, the positions we took, and links to the public record.

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The Team
The analytical bench behind the filings

A regulatory practice built on quantitative depth — data scientists, a financial modeler, a policy analyst, and market veterans who have run industrial energy portfolios from the inside.

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Contact

Get in touch

Harper Advisory works with a focused number of clients where expertise is directly relevant. If your organization faces meaningful regulatory, commercial, or procurement challenges in US electricity markets, we welcome the conversation.

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