What we do
Regulatory outcomes are set in rooms where industrial energy users are often outnumbered. Harper Advisory represents large energy consumers in state utility commission proceedings, ISO/RTO stakeholder processes, and state agency matters — providing expert witness testimony, formal comments, settlement participation, and sustained policy engagement.
The practice is built on operating experience. Before founding Harper Advisory, Sam Harper managed energy for major North American steel producers and served six years on the ERCOT Board of Directors (2016–2021), including through Winter Storm Uri. That background shapes advocacy that speaks to how industrial facilities actually operate — interval load profiles, process constraints, and the economics of energy-intensive production.
We also monitor state legislative and federal regulatory developments affecting industrial energy users, so clients see changes coming before they land in a tariff.
Where we practice
Current and recent work spans the CPUC (general rate cases, rate design, demand response, dynamic pricing), the PUCT (large load interconnection standards, 4CP transmission cost recovery), CARB (Cap-and-Invest rulemaking), ERCOT protocol revision processes (NPRRs and PGRRs affecting large loads), and PJM — regulatory monitoring and insights for clients on PJM capacity market proposals and demand response.
We serve as regulatory consultants to coalitions including the California Large Energy Consumers Association (CLECA) and the ERCOT Steel Mills, alongside engagements for individual industrial clients. Selected filings are listed on our Filings page.
Facing a related regulatory or commercial question? Harper Advisory works with a focused number of large industrial energy users across ERCOT, CAISO, PJM, and other US markets.
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