Regulation - HMS Legal

Surviving in Post-Hommrich Pennsylvania

Todd Stewart on August 21, 2023

Two and a half years ago the Pennsylvania Supreme Court affirmed Commonwealth Court Judge Michael Wojcik’s Opinion in Hommrich v. Commonwealth of Pennsylvania, Pennsylvania Public Utility Commission; 231 A.3^rd 1027 (Pa. Cmwlth. 2020). A recent review of the net metering applications and other requirements of several Pennsylvania electric distribution companies (EDC’s) demonstrates that some EDCs have not implemented the holdings of the Hommrich decision in these important informational and decisional materials for customers and developers. To fully promote the General Assembly’s intent of incentivizing alternative energy through net metering, the Public Utility Commission (PUC) should require stricter compliance with the law as interpreted in Hommrich.

In Hommrich, the Commonwealth Court held that several regulations (52 Pa. Code §§ 75.01, et seq.), which were promulgated over the objection of the Independent Regulatory Review Commission (IRRC), went beyond the statutory authority conferred on the Public Utility Commission (PUC) under the Alternative Energy Portfolio Standards Act (Act) and that those provisions were contrary to the requirements of the Act. 73 P.S. §§ 1648.1, et seq. The effect was to invalidate several sections of the PUC’s regulations.

Specifically, the PUC’s definition of “customer generator” was found to add a requirement not found in the Act, that a customer generator be a “customer” of the utility, thus implying the need for independent load. The stricken regulations also included a definition of “utility” which is not in the Act. The court made it clear that the Act’s definition of Customer Generator does not require any electrical use beyond the needs of the facility itself “a nonutility owner or operator of a net-metered facility may utilize net metering so long as “any portion” of the electricity that the customer-generator generates is used to offset part of the customer-generator’s electrical requirement”. Id. The court invalidated the definitions of customer generator and utility. In furtherance of its view that no independent load is required to qualify for net metering, the court also struck 52 Pa. Code § 75.13(a)(1) which required load that had a purpose other than to support the operation, maintenance or administration of the alternative energy system to be present for a project to qualify for net metering.

Despite the court’s holdings that prohibit EDCS from denying net metering eligibility on the basis of lack of customer status or independent load, EDCs continue to have language in customer-facing documents that imply customer generators without independent load may not qualify for net metering.

For example, one EDC’s net metering application requires an applicant to acknowledge that “operation of Customer’s generation facility is intended primarily to offset part or all of a customer’s electricity requirements.”[1] Regardless of the EDC’s intent or lack thereof, this phrase is clearly incorrect and misleading, and may confuse or scare off unknowing potential net metering projects. EDC’s customer or developer facing documents should not contain requirements inconsistent with the law.

Other EDC’s have similar provisions in their application. For example, another EDC’s application asks if the applicant intends to “export” power without defining “export”. The available multiple choice answers include: “Yes, Significant annual export/No net-metering/IPP” (emphasis added), suggesting that if a project is going to produce significantly more energy than it consumes that it is not eligible for net metering, which is contrary to the Act.[2] This EDC recently revised its net-metering application to take out language related to the 2007 version of the Act. There are likely other examples.

The PUC is no better when it comes to keeping its regulations current. While the PUC did withdraw a policy statement that had limited the size of third-party owned net-metered projects, to 110% of the customer-generator’s annual electric consumption, the PUC order was issued a year after the Supreme Court affirmed the Commonwealth Court’s Hommrich decision.[3] The regulations at issue were stricken in 2021 and the PUC has yet to clean them up to reflect their status, nor has the PUC holistically required EDCs to modify their forms or applications to reflect the state of the law after Hommrich. To ensure EDCs are appropriately applying net metering standards and rules, it would be best for the PUC to investigate what EDCs are stating when interacting with potential net metering project developers and provide specific guidance on what net metering related forms and agreements should and should not say. Likewise, the PUC should remove the stricken sections from its regulations so that the unsuspecting public is aware that the law has changed.

[1] https://www.pplelectric.com/site/-/media/ppl-jss-app/assets/Home/More/For-Construction/DER-Management/docs/PPL-EU-Net-Metering-Rider.ashx.

[2] https://www.firstenergycorp.com/content/dam/feconnect/files/retail/pa/PA-Level-234-Interconnection-Application.pdf.

[3] Net Metering – The Use of Third-Party Operators; Docket M-2011-2249441 (Order entered February 24, 2022).

Christopher Knight of HMS Discusses Insurance Regulatory Issues at PAMIC’s Market Regulation Seminar

Melissa Chapaska on May 10, 2017

FOR IMMEDIATE RELEASE

May 10, 2017

On May 10, 2017, Christopher Knight of Hawke, McKeon & Sniscak, LLP participated for the third consecutive year as a speaker at the Pennsylvania Association of Mutual Insurance Companies’ Market Regulation Seminar, which took place at the Harrisburg Hilton.

Reflecting on recent decisions by the Pennsylvania Insurance Commissioner, Mr. Knight tackled legal issues affecting umbrella and excess liability insurance policy cancellations, and participated in a panel discussion regarding recent Insurance Department enforcement actions.

In addition to Mr. Knight, the PAMIC Seminar also featured Chris Monahan, Deputy Commissioner for Market Regulation for the PA Insurance Department, as well as Jason Ernest, Deputy CEO and Counsel to the Insurance Agents & Brokers Association.

Founded on extensive experience in administrative law, Hawke, McKeon & Sniscak LLP specializes in legal issues affecting regulated industries. For more information on the firm, please visit us at www.hmslegal.com.

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Hawke, McKeon & Sniscak, LLP

100 North 10^th Street

Harrisburg, PA 17101

(717) 703-0804

http://www.hmslegal.com

PUC Requests Comments on Taxi Regulations

Whitney Snyder on August 12, 2016

On August 11, 2016, The PUC acting pursuant to Act 85 of 2016, which requires the PUC to promulgate new regulations in response to changes in the industry, requested public comment on ride sharing companies such as Uber and Lyft. Uber and Lyft have spurred and created controversy in both the Public Utility Commission (PUC) and Commonwealth Courts. The PUC requested comments include “specific suggestions for any proposal, including suggested regulatory language, with appropriate citations to current regulations that address the particular comment. Additionally, comments must provide the underlying rationale to support any suggested temporary regulations.” Comments are due 30 days from publication in the Pennsylvania Bulletin, which is published each Saturday. The rulemaking is docketed at L-2016-2556432.

The Act also exempts the PUC from certain procedural regulatory review standards under the Commonwealth Attorneys Act and Regulatory Review Act.

The Commission’s temporary regulations will address the following topics:

(I) the use of log sheets and manifests, including the storage of information on digital or other electronic devices.

(II) metering addressing the use of a variety of technologies.

(III) vehicles’ age and mileage, including procedures to petition for exceptions to age and mileage standards.

(IV) marking of taxis, including advertising.

(V) the operation of lease-to-own taxi and limousine equipment subject to the following conditions:

(a) providing required levels of insurance on the vehicle.

(b) ensuring that the vehicle is subject to and complies with all vehicle inspection requirements.

(c) ensuring that the driver complies with all the requirements of 52 Pa. Code Ch. 29 subch. F (relating to driver regulations).

(d) terminating insurance provided to a driver who completes the purchase of the vehicle or who no longer provides driver services to the taxi or limousine company.

(VI) taxi tariffs, including rate and tariff change procedures for both meters and digital platforms. Regulations shall reflect reduced or flexible rates and tariffs as appropriate.

(VII) procedures for cancellations, no-shows and cleaning fees.

(VIII) limousine tariffs, including rate and tariff change procedures. Regulations shall reflect reduced or flexible rates and tariffs as appropriate.

(IX) driver requirements, including criminal history background check requirements and driving record requirements.

(X) vehicle requirements, including compliance with environmental, cleanliness, safety and customer service standards, including special safety requirements for children.

(XI) requirements for continuous service and exceptions for unexpected demand and personal health and safety.

The Act requires the PUC to promulgate temporary regulations by December 2016 (150 days from the effective date of the Act). The temporary regulations will expire at the earlier of the PUC’s promulgation of final-form regulations or two years from the effective date of the Act.

IRRC Shoots Down AEPS Regulations a Second Time

Todd Stewart on July 7, 2016

When Pennsylvania’s Independent Regulatory Review Commission (“IRRC”) voted unanimously at its June 30, 2016 meeting to disapprove for a second time the Pennsylvania Public Utility Commission’s (“PUC”) recent efforts to modify its regulations implementing the Alternative Energy Portfolio Standards(“AEPS”) Act,[1] it was aware that its action would at most place a speed bump in the PUC’s path, but it disapproved the regulations anyway.

The issue is the PUC’s proposed definition of “utility” and its impact on the future of Pennsylvania’s alternative energy market. Questioning the PUC’s representative, IRRC Commissioners tried repeatedly to get an admission that any sale of excess production from a net metered facility to an electric distribution company will make the seller a “public utility” under the PUC’s definition, to which he repeatedly responded “I disagree,” without elaborating. In the end, IRRC was unconvinced by the PUC’s position and voted to disapprove the regulations.

Procedurally, if the PUC decides to promulgate the regulations, the only possible roadblock would be the speedy passage of a General Assembly concurrent resolution, that the Governor must then sign. This approach seems unlikely given the status of the budget and the current legislative recess.

What is clear from the discussions so far is that the PUC has declared war on “merchant generators”. While the term “merchant generator” does not appear in the AEPS Act, and is nowhere defined in the proposed regulations, it nonetheless appears 21 times in the PUC’s Order that sent the proposed regulations to IRRC before this last rejection. A fair reading of the PUC’s Order reveals that the PUC believes that merchant generators are receiving net metering subsidies to which they are not entitled. Despite the efforts of IRRC to uncover the source of the PUC’s belief, the PUC produced no evidence to support this view. When one considers that the PUC’s proposed regulations also include a requirement that the PUC approve all net metering applications for projects over 500 KW, it seems fairly certain that the PUC is proposing a methodology by which it can exclude those whom it determines to be “merchant generators” from participating in net metering.

The PUC’s anti-merchant generator strategy is two pronged. First, it capped the size of entities that could participate in net metering at 200% of “independent load”[2]. Second, it defined “utility” in such a way as to allow the PUC to claim that “merchant generators” are “utilities”, and thus render them ineligible for net metering. The definition of “utility” is important because the statute uses the term “nonutility” to modify the terms “owner or operator” in the definition of “customer generator.”[3] So an entity that is a “utility” cannot be a “customer generator”. When the first prong (the 200% cap) was expressly rejected by IRRC, the definition of “utility” became critical. This was born out at the IRRC hearing where the PUC representative said that currently there are only two types of entities that meet the definition of utility: EDCs (i.e., traditional electric companies that are undeniably utilities); and electric generation suppliers (“EGSs”). The PUC is tossing EGSs into this game of “who is a utility” because EGSs provide electric generation supply service, which the PUC conveniently included in its definition of what makes you a utility. The rub is that the Public Utility Code makes it clear that EGSs are not public utilities except for very limited purposes enumerated in the code, and the AEPS Act is not one of those limited purposes.[4] The PUC’s end game is to define “utility” such that any entity that is not an owner of a project, i.e., an operator, that sells excess electricity back to the EDC, is an EGS and thus is not eligible for net metering. If allowed to be become effective, the changes will outlaw a business model employed by many renewables projects, both existing and planned, across Pennsylvania.

While we await the IRRC order disallowing the proposed regulations, it seems fairly certain that, failing the General Assembly and Governor moving very quickly, the only protection for project developers, particularly existing operating projects, may be to seek pre-enforcement review in the form of declaratory/injunctive relief from the Commonwealth Court.

[1] 73 P.S. §§ 1648.1, et seq.

[2] The term “independent load” also is not defined, or required, by the AEPS Act.

[3] 73 P.S. § 1648.2.

[4] 66 Pa. C.S. §§ 102, 2809, 2810

North American Leaders Announce Climate, Clean Energy, and Environment Partnership

Melissa Chapaska on June 30, 2016

On June 29, 2016, President Obama, Prime Minister Trudeau, and President Nieto announced the North American Climate, Clean Energy, and Environment Partnership at the North American Leaders Summit. According to President Obama, the “ambitious and enduring” Partnership will see the United States, Canada, and Mexico “work toward the common goal of a North America that is competitive, that encourages clean growth, and that protects our shared environment.”[1]

Key features of the Partnership include:

Participation in the Paris Agreement, a United Nations agreement that aims to keep global warming below 2°C through the development of low greenhouse gas emission strategies.

Achievement of 50% clean power generation for North America by 2025 – what President Obama called a “bold” but “imminently achievable goal” – through a range of initiatives, including 5,000 megawatts of cross-border transmission projects to facilitate the deployment of clean power.

Reduction of methane emissions from the oil and gas sector by 40-45% by 2025 through the development and implementation of federal regulations, programs, and policies.

Reduction of black carbon emissions by implementing heavy-duty vehicle diesel fuel and exhaust emissions standards by 2018 and deploying renewable energy alternatives to diesel, coal, or firewood.

Promotion of clean and efficient transportation through emission reduction standards for heavy-duty and light-duty vehicles and maritime shipping.

Conservation efforts aimed at migratory species and ocean management.

Completion of the inefficient fossil fuel subsidies phase out by 2025, agreed to as part of the G-20’s 2009 commitment.

In addition to these overarching goals, the United States also specifically committed to purchase more clean energy for federal facilities and government vehicles and seek to finalize a rule to prohibit the use of certain high-global warming hydrofluorocarbons (HFCs) under the Significant New Alternatives Policy (SNAP) program.

While the White House Climate Advisor called the Partnership targets “achievable continent-wide” and “supported by domestic policies,”[2] only time will tell if all three countries will be able to implement the programs and pass the regulations needed to meet the ambitious Partnership goals.

[1] Katie Reilly, Read the Remarks from the ‘Three Amigos’ Summit Press Conference, available at http://time.com/4388789/three-amigos-summit-transcript-obama-nieto-trudeau/ (June 29, 2016).

[2] Press Release, available at https://www.whitehouse.gov/the-press-office/2016/06/29/press-gaggle-press-secretary-josh-earnest-and-senior-advisor-president (June 29, 2016).

PIPES Act Update

Judith Cassel on June 23, 2016

Yesterday, President Obama signed into law the “Protecting our Infrastructure of Pipelines and Enhancing Safety” (PIPES) Act. This bi-partisan bill was the culmination of efforts by both the Energy and Commerce Committee and the Transportation and Infrastructure Committee. This Act is intended to increase the efficiency and transparency of the Pipeline and Hazardous Materials Safety Administration (PHMSA) while enlarging safety inspections and audits of the natural gas pipeline industry.

PIPES focuses on PHMSA almost as much as it focuses on pipelines. The Act reauthorizes PHMSA’s pipeline safety program for another 4 years. The Act forces PHMSA to complete the directives it was supposed to complete by 2015, but failed. PHMSA must now update Congress every 90 days on outstanding statutory mandates. Additionally, the Government Accountability Office (GAO) will conduct studies into the effectiveness of PHMSA’s integrity management programs.

The Act also focuses on additional inspections and scrutiny for pipelines in coastal areas, marine waters, and the Great Lakes. These pipelines will now have a new designation of “unusually environmentally sensitive.” But along with the heightened scrutiny is an effort to help the industry comply with new safety regulations by sharing new technologies that increase safety and protect the environment.

President to Sign New Natural Gas Safety Act

Judith Cassel on June 16, 2016

Tuesday night, the U.S. Senate passed the Protecting our Infrastructure of Pipelines and Enhancing Safety Act (PIPES Act). This bill is now headed to President Obama to be signed into law. In addition to reauthorizing the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) through FY2019, this soon-to-be law enacts substantive changes in the pipeline industry’s regulatory landscape.

Highlights of Act

Increases authority for the Secretary of Transportation to quickly impose restrictions in the event of a serious accident
Increases state funding to run more aggressive pipeline inspections
Institutes state and federal collaboration on pipeline mapping
Insures collaboration between state and federal investigators on regular safety, as well as post-accident, inspections and investigations
Assesses PHMSA’s integrity management programs for liquid and natural gas pipelines
Provides for greater transparency and publication of reportable releases
Contemplates creation of new safety standards for underground natural gas storage facilities with permission for states to go above these standards
Creates task force to investigate causes and impacts of the Aliso Canyon natural gas leak
Imposes new fees on entities operating underground natural gas storage facilities
Increases inspection requirements of specific underwater oil pipelines
Mandates research, testing, and publication of innovations in pipeline materials, corrosion prevention, and training
Authorizes PHMSA to establish a nationwide database of oversight activities

This bill was originally introduced in the Senate by Nebraska Republican Senator, Deb Fischer, but gained overwhelming bi-partisan support, passing the House with very few amendments and the Senate with unanimous consent.

The Aliso Canyon natural gas leak, the San Bruno and Philadelphia gas explosions and the BP Gulf of Mexico Deep Horizon spill all served to highlight to the U.S. Congress, and its constituents, the inherent dangers that are possible with the exploration, transmission and use of natural gas. These natural gas accidents coupled with the proliferation of new pipelines serving the recently accessible shale gas in the Northeast, served as a motivation for the PIPES Act.

What does the future hold for Pennsylvania’s competitive energy markets?

Todd Stewart on October 17, 2014

As the PA PUC embarks on its investigation of the natural gas markets, what evidence can we discern about how the agency sees competitive energy markets and how those markets should evolve?

On August 21, 2014, the PUC issued a Tentative Order that identified a laundry list of issues that its Office of Competitive Market Oversight (“OCMO”) will be tasked with investigating. The list includes such items as the assignment of storage and pipeline capacity, tolerances/penalties for system balancing, customer education and switching timeframes, to name a few. However, the list is perhaps most notable for issues not included. There will be no discussion of the natural gas distribution companies (“NGDC”) exiting the merchant function and no discussion of standard offer referral programs.

Looking first at the issues that will be examined, many involve nuts and bolts operational issues. Capacity assignment, switching timeframes, access to on-system delivery points, and so on. Improvements in the efficiency and fairness of these aspects of the interaction between natural gas suppliers (“NGS”) and NGDCs will make the market more seamless, reduce costs for NGSs and potentially NGDCs, and will provide a better customer experience. All of these would be good outcomes, and I am not aware of any party that opposes taking a look to see what tweaks or even more substantial changes are needed. This operational focus– regulating the market and making sure the existing structure works as best it can – is something the PUC views as within its wheelhouse, an area of core competency.

Devoting time to competitive market operational details, however, diverts resources and attention from the larger issues that will decide whether Pennsylvania’s competitive market will endure and thrive. For now, at least, it appears the PUC wants nothing to do with any discussion of NGDCs exiting the merchant function. There could be several reasons for the Commission’s reticence, considering that only a few short years ago, the Commission appeared to be seriously considering programs in the electricity markets that could have transitioned many customers into the competitive market, and at least one electric distribution company was seriously considering a formal exit. One possible explanation is that the Commission has what golfers call a case of the “yips” — the inescapable feeling that you have lost your “game” which results, inexorably, in losing your game. The loss of confidence started with the abrupt manner in which the electric market RMI process was turned around at the last possible minute, dropping programs that would have transitioned many customers to competitive service. Last year’s “polar vortex,” which brought the PUC undeserved criticism for “allowing” a roiling of the retail electric markets, when the problem was a wholesale market issue, slowed forward progress even more. The fallout from that period is still being felt. The Commission promulgated regulations to police disclosure of variable rates; while House Consumer Affairs Committee Chairman Godshall wanted legislation that would have imposed rate regulation on “deregulated” retail EGS rates. The resulting, and rather public, falling out between Chairman Godshall and Commission Chairman Powelson seems to have made the PUC even more reluctant to take bold action. It seems clear that there simply is not the political will, and possibly not the political capital, to advance the deregulation agenda that the Commission clearly signaled in the past, especially in light of the impending gubernatorial election.

But neither the polar vortex aftermath nor politics explains why the PUC has shied away from at least examining whether standard offer programs, so successful in electric deregulation, should be used in natural gas retail choice programs. Standard offers were responsible for migrating many customers off of default service and into one year fixed rate electric contracts. Perhaps the Commission is taking a practical approach, waiting to see what happens at the transition when the one year electricity contracts expire to make sure that it has a handle on the issues that can crop up. Perhaps the Commission wanted to wait and see whom the voters pick on the first Tuesday in November, to see how things change across the street—if at all. Regardless, it may be that the very fact that the Commission chose to wait and see rather than move ahead with a program, even if doing so appears, by most accounts, to be rational, is a signal of a change in attitude at the PUC. More practical, less policy – at least for now. The recent focus on the passage of House Bill 939, the re-authorization of Chapter 14, which also includes the authorization for the Commission to assess NGSs and EGSs, may be further evidence of this approach.

What does all this mean for the future of energy markets, natural gas and electricity, in Pennsylvania? In the short term it probably means that the Commission will appear to be unwilling to go down the road of opening the natural gas RMI proceeding to include issues related to merchant function exit, even if the enabling legislation expressly provides for such a result. It means the RMI will remain focused on operational issues. In the electricity markets, it appears unlikely that there will be any new proceedings to address the competitive market, at least until people stop holding their collective breath over concern about the potential repeat of last winter’s extreme run-up in wholesale prices. In other words, nuts and bolts are fine, but let’s not get into any policy fights just now.

In the long term, things may be more hopeful for those seeking change in the structure of the retail energy markets, if we can put the remnants of the recent past behind us and step out from under the microscope long enough. Both gubernatorial candidates appear to favor competitive markets, although it is not clear how far either would go toward endorsing significant market changes at this juncture. It does not appear that the positions of the individual Commissioners on competitive markets have changed, either. Rather, it appears that circumstances outside their control have forced them to take the practical road for now.

So what does the future hold? The answer is, it depends. As is so often the case, policy in this area is dictated by reactions to current events. It depends on how volatile the retail markets become, and to a lesser extent, the cause of that volatility; it depends on who wins the race for governor, and the makeup of the Commission; and it depends on the marketers deciding to remain in Pennsylvania and staying engaged in the process. This last factor may be the most important.

New Federal Insurance Office gets a Director, but will it get regulatory authority?

Christopher Knight on June 24, 2011

Michael McRaith officially began his new job earlier this month as the first Director of the Federal Insurance Office (FIO or Office) after serving for the past six years as Director of the Department of Insurance in President Obama’s home state of Illinois. The FIO was established by the Dodd-Frank financial reform legislation of 2010 as an office within the U.S. Department of the Treasury, and represents a part of the Congressional response to concerns about the financial stability of certain large domestic insurers and their subsequent taxpayer bailouts in 2008 and 2009. Director McRaith will report to Treasury Secretary Timothy Geithner.

At this time the FIO has only an advisory role and monitoring authority over the business of insurance, while regulatory authority remains vested at the state level. However, the establishment of the Office has caused a great deal of speculation, both within the industry and among state regulators, regarding whether it represents a significant first step towards shifting insurance regulation to the federal level in the future.

Whether federal insurance regulation becomes a reality may ultimately depend on the continued financial security of major insurers in the U.S., since further perceived instability could increase the pressures on state regulators to prove to Congress that the current system remains the most effective option.

For now, Director McRaith will have the opportunity to help shape the new Office’s role, which includes responsibility to recommend to the (also new) Financial Stability Oversight Council (FSOC) those insurers that should be subject to regulation by the Federal Reserve System due to a determination that their financial (in)stability poses a risk to the national financial system. The Office will also advise the Treasury and White House on insurance matters, report to Congress about the industry, and have some limited preemption authority over state laws that affect international insurance arrangements. The contents of an FIO report due to Congress in early 2012 regarding the status of insurance regulation could provide the first tangible indications of future agenda-setting for possible shifts in regulatory responsibilities; it will certainly have the full attention of industry stakeholders looking for clues about the future oversight of the business of insurance in the United States.

Former Insurance Department Counsel joins firm

Kevin McKeon on May 3, 2011

Hawke McKeon and Sniscak LLP, is pleased to announce the expansion of its insurance regulatory practice, with Christopher J. Knight joining the firm as Of Counsel.

Chris spent nearly nine years as Counsel for the Pennsylvania Insurance Department as a member of the Governor’s Office of General Counsel, and will now use that experience and knowledge in his representation of insurance companies, producer licensees and other insurance-entity clients in regulatory, licensing and government compliance matters and related litigation.

During his career with the Insurance Department, Chris represented the Insurance Commissioner and Department regarding regulatory matters in all lines of insurance, and had lead responsibility for litigated matters in the Pennsylvania Supreme Court and Commonwealth Court, as well as before the Department’s Administrative Hearings Office. He frequently coordinated enforcement investigations and administrative prosecutions related to company and producer legal compliance and licensing, including multi-state investigations of major international insurance companies and brokers. Most recently, Chris served from 2009-2011 as lead attorney for the MCARE Fund, Pennsylvania’s statutory contingency fund, providing required medical professional liability excess coverage for doctors and hospitals.

Prior to joining the Insurance Department, Chris spent five years in the private practice of law, serving as lead counsel in numerous jury trials in courts throughout Pennsylvania. He has lectured regarding insurance regulation and litigation and served as a presenter and panelist at various continuing education seminars, and has taught trial advocacy to law students on numerous occasions.