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.

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. Includes monitoring of state legislative and federal regulatory developments affecting industrial energy users.

Rate Cases Expert Testimony CPUC · PUCT ISO/RTO Stakeholder
Commercial

Energy market strategy and commercial guidance calibrated to the realities of industrial buyers — commodity risk management, energy contract negotiations, demand response program participation, and operational strategies to minimize delivered energy cost. Includes support for new and expanded load interconnections, working with utilities and ISOs to navigate interconnection processes, tariff design, and commercial terms.

Risk Management Contract Negotiation Demand Response Load Interconnection
Renewables & Storage

Renewable energy and battery storage advisory for industrial buyers: technology and site feasibility, Private-Use-Network configuration, behind-the-meter BESS analysis, RFP development and management, developer and vendor proposal assessment, tariff and market savings quantification, RPS compliance strategy, and commercial negotiation support through project execution.

PPA Structuring BESS Feasibility RFP Management PUN Configuration RPS Compliance
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.

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.

Public Record

Selected regulatory filings

CPUC links open filings on docs.cpuc.ca.gov. PUCT links open filings on the PUCT Interchange system. Confidential client matters are not listed.

Principal

Sam Harper

Sam Harper, Principal, Harper Advisory LLC
Sam Harper
Principal, Harper Advisory LLC
Sam Harper at a wind energy facility

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.

Sam Harper advises organizations that engage across the energy supply chain, with a particular focus on large energy consumers for whom energy represents a significant percentage of the cost of production. His practice spans energy procurement, utility regulation, ISO/RTO governance, renewable energy development, and demand response, with direct commercial and regulatory experience in PJM, MISO, ERCOT, CAISO, IESO, CENACE, and various unorganized markets.

Prior to consulting, Harper served as Director of Energy for Gerdau's North American operations from 2013 to 2022. Gerdau is a major steel producer with significant energy requirements and active demand response participation. During his tenure, he held a series of positions including Regional Energy Manager and Assistant Vice President of Operations for Gerdau's subsidiary load-serving entity. His responsibilities included demand response operations, RTO/ISO stakeholder processes, utility regulatory intervention, commercial energy contract negotiations, commodity risk management, and renewable energy development.

Before that, Harper was employed from 2008 to 2013 by ArcelorMittal, a global steel producer, ending his tenure as Sourcing Manager of Electricity for US Operations. During that time, he created and managed a load-serving entity and curtailment service provider in the PJM territory.

Elected in 2025 to represent the Commercial and Industrial (C&I) customer sector on the Regional Organization for Western Energy (ROWE) Nominating Committee to seat its first independent board.
Elected each year from 2016 through 2021 to the Board of Directors of the Electric Reliability Council of Texas (ERCOT). Served on the Human Resources and Governance Committee throughout his tenure; elected Vice-Chair in 2021. Served during the Winter Storm Uri reliability crisis in February 2021 and its aftermath.
Advisory Board, Renewable Development Fund of Minnesota, 2017–2020, overseeing the prudent award and execution of renewable energy grants aligned with state policy goals.
Bachelor of Science in Business Administration, University of Illinois at Urbana-Champaign, 2008 — Honors
Our People

The Harper Advisory team

Coleman Nickum
Coleman Nickum
Energy & Policy Analyst

Coleman supports Harper Advisory's regulatory and policy research across energy markets and proceedings. His background spans environmental and energy policy work at the Texas Commission on Environmental Quality, an Energy Policy Fellowship with the Texas Energy and Climate Caucus at PowerHouse Texas, and an environmental compliance internship at Cheniere Energy. He holds a Professional Science Master's in Environmental Analysis from Rice University and a B.S. in Environmental Science from Baylor University.

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Jayashree Dommara
Jayashree Dommara
Data Science Consultant

Jayashree brings deep data science expertise to Harper Advisory's analytical work. Prior to consulting, she spent nearly four years at Mu Sigma delivering end-to-end data solutions for a Fortune 10 firm — including commodity trading dashboards, price prediction models, and optimization algorithms generating measurable financial outcomes. She holds a Master's in Business Analytics from the University of Illinois Urbana-Champaign and a Bachelor of Engineering in Electrical and Electronics Engineering from St. Joseph's College of Engineering.

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Dave Forsyth
Dave Forsyth
Energy Consultant

Dave brings broad experience in energy procurement for large industrial operations, ISO and utility regulation, wholesale power market settlements, retail energy contract negotiation, industrial demand response, and renewable energy development across PJM, ERCOT, MISO, CAISO, NYISO, and IESO. He currently serves on the Ontario IESO Technical Panel representing the Association of Major Power Consumers in Ontario. Prior to consulting, he was Director of Energy Market Operations at Rodan Energy Solutions, and spent a decade as Regional Energy Manager at Gerdau.

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Sharon Mosesi
Sharon Mosesi
Project Manager

Sharon serves as project manager at Harper Advisory, coordinating client engagements across regulatory proceedings, commercial advisory work, and firm operations. A geographer and GIS specialist by training, she brings expertise in environmental management, regulatory compliance, and spatial data analysis. Prior to Harper Advisory, she spent four years as a GIS Specialist at Koleko Civil Engineering & Planning in South Africa. She holds a BSc Honours in Geography and Environmental Science from the University of Pretoria and ISO 14001:2015 Environmental Management Systems certification.

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John Holler
John Holler
Analyst

John focuses on building financial models and quantitative analysis in support of Harper Advisory's client engagements. His background includes energy-sector commercial analysis developed during a career at ExxonMobil and its joint venture RasGas, where he held a series of commercial and analytical roles. He holds a Bachelor of Science and an MBA from the University of Florida.

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Camille Dimarucot
Camille Dimarucot
Data Analyst

Camille applies advanced analytics to energy market challenges — analyzing energy supply contract economics, renewable energy development opportunities, and consumption patterns to drive data-driven decisions for clients. She develops financial scenario analysis and quantifies the economic impact of regulatory opportunities and commercial negotiations. Prior to Harper Advisory, she was a Senior Business Analyst at RingCentral, where she led reporting and analytics across global sales teams. She holds a Bachelor of Arts in Economics from the University of the Philippines.

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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.

Address
Harper Advisory LLC
9002 Six Pines Drive
Shenandoah, TX 77380
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