Grace Dickson Gerbas

GRACE DICKSON GERBAS focuses her practice on energy-related matters, counseling energy industry clients on regulatory and transactional issues. She has significant experience negotiating and structuring agreements for long-term natural gas, solar, and wind offtake arrangements; renewable energy credit (REC) purchases; and revenue structures for projects across major U.S. power markets. Grace also regularly advises on and negotiates power purchase arrangements in connection with data centers, addressing the unique reliability and risk considerations critical to data center operations.

Grace works with clients on complex trading, hedging, and collateral arrangements involving electricity, environmental attributes, carbon credits, natural gas, and other commodities. In addition, she provides guidance on critical project contracts, including energy management and operations and maintenance agreements. She further advises utilities, developers, and financial institutions on acquisitions and compliance, and has represented electric utilities before the Federal Energy Regulatory Commission (FERC) and state public utility commissions. By integrating regulatory insight with deal execution, she helps clients anticipate risks, align with evolving policy, and achieve their business objectives efficiently.

Grace earned her J.D. from Southern Methodist University Dedman School of Law, where she was the editor in chief of the SMU Science and Technology Law Review. Prior to attending law school, she was a field representative for the Office of U.S. Senator Heidi Heitkamp (ND). After graduation, Grace served as a term law clerk for Magistrate Judge Charles S. Miller, Jr. for the U.S. District of North Dakota. Prior to joining Sidley, she was an energy associate at another international law firm.

Grace’s recent representative experience includes:

• VoltaGrid LLC, a U.S.-based clean energy innovator, in its strategic collaboration with Oracle Corporation to deliver more than 2,300 megawatts (MW) of ultra-low-emissions power infrastructure to support the energy demands of Oracle Cloud Infrastructure’s next-generation artificial intelligence (AI) data centers.
• Dairyland Power Cooperative in connection with the construction of a 765 kV interstate transmission line and associated facilities, to be co-owned and constructed by Dairyland and other partner utilities.
• Key Capture Energy in ongoing proceedings at FERC related to Central Hudson Gas and Electric Corporation’s proposed rate schedule for Wholesale Distribution Service.
• EDF Trading North America LLC in a high-stakes FERC proceeding that set a powerful new precedent for generators providing essential reliability services to the California grid.
• Citigroup Energy, Inc. with regulatory compliance, structuring, and documenting natural gas asset management agreements.
• An electricity generation and transmission cooperative in connection with the planned purchase of three power generation assets in the PJM market.
• An energy and commodity trading business in a complex natural gas enforcement case involving violations of Federal and Exchange position limits as enforced by both the CFTC and ICE.
• A renewable energy company in negotiating a 17-year agreement for the sale of capacity and energy from a clean energy resource, including associated non-power attributes, to a regional utility, in compliance with state clean energy legislation.
• An international energy company as purchaser in the sale by an affiliate of NRG Energy, Inc. (NRG) of equity in a company that controls a 385 MW combined cycle natural gas facility — the Gregory Power Plant — located near Corpus Christi, Texas in the AEP Central service area in ERCOT.
• A global energy commodities trader in regulatory matters before FERC related to its natural gas marketing activities, including with respect to gas transportation services agreements and storage.
• An energy and commodity trading business on all aspects of FERC gas regulatory matters, including counseling arising from the disruption of the gas market caused by the commence of commercial operations by the Mountain Valley Pipeline and Platts, changing the definition for a critical index pricing point.
• A multinational commodity trading and mining company with respect to natural gas pipeline regulations, including shipper requirements surrounding pipeline capacity procurement and FERC’s capacity release regulations.
• An electric cooperative in its US$800+ million securitization transaction to finance the ERCOT power costs associated with the Texas February 2021 Storm.
• Clients in proceedings before the Public Utility Commission of Texas associated with the Texas February 2021 Storm.
• A client before the Public Utility Commission of Texas on issues related to the ERCOT market design.
• Clients in administrative litigation and settlement negotiations before the FERC.
• A foreign government in federal litigation proceedings relating to the operation of an oil pipeline.
• A client in Term B loan financing for a US$520 million purchase of an international mining services business.

Some of the above matters were handled prior to joining Sidley.

• Energy Bar Association – Texas Chapter Board Member