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C.J. Polito
C.J. Polito
Partner — Energy Regulation
E: cjpolito@velaw.com T: +1.202.639.6781
VCard BIO PDF
Partner — Energy Regulation

C.J. Polito

C.J. Polito
Washington, D.C.
T: +1.202.639.6781

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, D.C. 20037

E: cjpolito@velaw.com
M: +1.440.537.4769
VCard BIO PDF
start quote symbolHe is fast, pragmatic and insightful. (Chambers USA, 2025)end quote symbol
C.J. Polito

C.J. represents clients on a variety of regulatory, enforcement, compliance and transactional matters involving the U.S. wholesale electricity and natural gas markets. He has extensive experience representing clients in regulatory proceedings and investigations before the Federal Energy Regulatory Commission (FERC), the North American Electric Reliability Corporation (NERC), the Commodity Futures Trading Commission (CFTC) and state energy regulatory agencies. C.J. regularly advises clients on physical and financial wholesale power transactions, mergers and asset acquisition approvals, regional energy market rules and tariff requirements, power purchase and sale agreements, and issues related to the design and operation of wholesale energy and capacity markets. He also advises energy companies, marketers, financial institutions, private equity funds and institutional investors and advisors on regulatory requirements under the Federal Power Act, the Public Utility Holding Company Act, the Natural Gas Act, and the creation and implementation of robust compliance programs.

C.J.’s practice focuses on federal energy regulatory matters related to the development, ownership and operation of electric generation and transmission projects. He counsels clients on energy regulatory issues related to various types of transactions involving electric projects. C.J. also advises clients on wholesale market participation rules and ongoing compliance with applicable FERC requirements.

C.J. has been recognized by Chambers Global in USA Energy: Electricity (Regulatory & Litigation) (2022–2025) and by Chambers USA in Energy: Electricity (Regulatory & Litigation) (USA–Nationwide, 2021–2025). Clients describe C.J. as “very communicative” further noting that “he provides a great work product” (Chambers Global, 2025).

Experience Highlights

  • Advising electric generation developers, energy companies and commodities trading firms on regulatory issues and related litigation under the Federal Power Act, the Natural Gas Act, the Public Utility Holding Company Act, and the Commodity Exchange Act

  • Representing wholesale power generation companies, holding companies, financial institutions and infrastructure funds in obtaining FERC authorization under Section 203 of Federal Power Act for acquisitions and dispositions involving FERC-jurisdictional assets

  • Representing multiple entities in obtaining FERC market-based rate authorization to sell electric energy, capacity, ancillary services and related services in various U.S. wholesale power markets, as well as with respect to obtaining exempt wholesale generator (EWG) and qualifying facility (QF) status

  • Advising entities in connection with due diligence and applications for FERC and state approvals involving variety of energy transactions

  • Representing energy and commodity companies, financial institutions and trade associations in regulatory proceedings before FERC, including rulemakings, ISO/RTO proceedings, and related filings

  • Providing regulatory advice related to ISO/RTO tariffs and agreements, including electric generator interconnection and transmission issues

  • Representing project developers, utilities and power marketers on all aspects of energy market regulation and compliance, including ISO/RTO market design issues, tariffs, market participation, credit and risk management

  • Representing energy trading company in FERC investigation and district court litigation involving alleged market manipulation and tariff violations

  • Advising clients on surveillance inquiries by FERC’s Division of Analytics and Surveillance involving market conduct in the natural gas and electricity markets

  • Advising energy trading companies in internal investigations and self-reports to FERC and CFTC

  • Conducting compliance training and drafting compliance handbooks for numerous energy trading companies on FERC and CFTC regulations

  • Representing financial institutions and commodities trading companies in investigations and inquiries by the CFTC’s Division of Enforcement and exchanges

  • Representing clients in wholesale power market design proceedings at FERC, including with respect to wholesale energy, capacity and ancillary services markets

  • Representing electric power generators in FERC proceedings to obtain compensation for reactive power supply services

  • Representing energy project developers in FERC proceedings regarding rate regulation, including battery energy storage system developers in FERC proceedings involving utility wholesale distribution service

  • Representing energy and commodities trading firms on structured transactions and energy trading agreements

  • Representing entities providing energy management services and tolling agreements for wholesale power generation facilities

  • Advising retail electric and natural gas providers in connection with participation in state retail markets

Credentials

  • Duke University School of Law, J.D., 2009 (James S. Bidlake Memorial Award, Editor, Duke Law Journal)
  • Georgetown University, B.A., magna cum laude, 2006 (Phi Beta Kappa)
  • Chambers USA, Energy: Electricity (Regulatory & Litigation), 2021–2025
  • Chambers Global, Energy: Electricity (Regulatory & Litigation), 2022–2025
  • Best Lawyers, “Ones to Watch,” Energy Law, 2022
  • Super Lawyers, “Rising Star,” Energy & Natural Resources, Washington, 2019 and 2020
  • Member, Energy Bar Association
  • District of Columbia
  • Illinois
  • “FERC Order Opens Wholesale Power Markets to DERs,” POWER Magazine, January 4, 2021 (co-author)
  • “What is ‘Resilience’, and Do We Need It?,” POWER Magazine, August 1, 2018 (co-author)
  • “Grid Reliability and Resilience: FERC’s Rulemaking and How Our Energy Markets Are Responding,” POWER Magazine, June 27, 2018 (co-author)
  • “‘Basic Fairness’ And The Future Of FERC Enforcement Proceedings,” Forbes, May 4, 2017 (co-author)
  • “How Trump’s Moves Will Widen The Federal-State Divide Over Energy Market Regulation,” Forbes, February 28, 2017 (co-author)
  • “What’s Next After the Aspire Commodities Ruling?” The National Law Journal, May 2016 (co-author)
  • “FERC Enforcement Report Emphasizes Internal Compliance Procedures, Self-Reporting, and Importance of Cooperation,” Pratt’s Energy Law Report, March 2015 (co-author)
  • “FERC Orders Trader to Pay $30 Million for Market Manipulation,” Financial Fraud Law Report, November/December 2011 (co-author)
  • “Kerry And Lieberman Introduce Much Anticipated Climate Change Bill,” The Environmental Counselor, July 2010 (co-author)
  • “FERC Proposes Credit Reforms for Organized Wholesale Electric Markets,” Electric Light & Power, February 2010 (co-author)
  • “FERC ALJ Finds Manipulation by Natural Gas Futures Trader,” Oil & Gas Financial Journal, January 2010 (co-author)

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