Steve's extensive regulatory expertise and commercial advice was invaluable during our critical startup phase as an Energy Services Company (ESCO). His guidance through the complex regulatory process at the state, regional and federal levels enabled our company to launch its business on time.
—CEO, private equity-backed

Stephen Humes advises clients on clean energy project development and finance, including renewables, nuclear facilities, powering data centers, including grid-scale and net-metered solar photovoltaics (PV), offshore wind, battery energy storage systems and geothermal.

For decades, Steve has advised clients on energy transactional, regulatory and environmental issues, including those associated with conventional and renewable power plant development, cogeneration, liquefied natural gas and pipeline facilities, geothermal and other utility infrastructure matters. His energy-related environmental experience includes advising clients on environmental due diligence, permitting, environmental justice and climate change issues. Steve guides clients through state and federal administrative proceedings, including advancing rate cases in administrative litigation and defending clients in enforcement actions. He also counsels clients on a full range of state and federal environmental compliance and enforcement matters and handles energy and environmental issues effectively in corporate mergers and acquisitions (M&A) transactions, including acquisitions and divestitures of power plants, nuclear facilities and renewable energy portfolios.

Representative Experience

  • Represented state energy agency on development and procurement contract negotiations representing billions of dollars in investments for more than 5,000 MW of offshore wind under development and 1,600 MW under construction in the Atlantic Ocean.
  • Represented project developers of solar PV and Battery Energy Storage System (BESS) projects across the United States and in Mexico, including negotiating PPAs, EPCs, easements and supply chain agreements.
  • Acted as general transactional and project finance counsel for 72 MW geothermal project operating successfully in Nicaragua and supported sale of project to new investors.

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  • Provided regulatory counsel for wholesale power generation and transmission asset owners before state public utility commissions and FERC.
  • Served as regulatory counsel in support of sale of nuclear power generation assets and nuclear decommissioning trust fund assets in New York.
  • Advised state-supported green banks on energy regulatory and renewable energy project finance matters to support solar PV, wind farms, biomass and biogas transactions, and green hotel financing transactions.
  • Counseled commercial real estate and multiunit housing clients on negotiating agreements for community solar and other renewable energy facilities and transactions involving renewable energy certificates.
  • Represented clients on energy regulatory and transactional matters in support of the nationwide deployment of electric vehicle (EV) charging stations.
  • Assisted owner of private water utility, sewage treatment plant and golf course development concerning SPDES permit enforcement and corporate transactions in New York’s Hudson River Valley.
  • Mediated natural gas procurement dispute successfully in energy litigation between a large group of institutional natural gas customers and a competitive energy supplier in New Jersey.
  • Led commercial arbitrations involving wholesale power generation, battery energy storage systems and construction disputes in geothermal project development in the United States and Central America.
  • Successfully represented respondents before the EPA in Clean Air Act environmental enforcement proceedings relating to motor vehicle idling and hazardous air pollutants.
  • Represented major wireless telecommunications carriers in cell tower development proceedings before Connecticut Siting Council and in litigation, including arguing the first State Supreme Court case to be heard nationwide on a key issue (See Zhang v. Omnipoint, 272 Conn. 627, 2005)—whether historic electric utility easements permit wireless antenna installations) and successfully litigated other important wireless facility siting issues (See Corcoran v. Connecticut Siting Council, 284 Conn. 455, 2007).
  • Assisted international energy company in identifying federal, state and local permitting issues and requirements in connection with major projects to develop marine LNG terminal facilities.
  • Advised international investors in acquisition or divestiture transactions involving conventional, nuclear and renewable power generation facilities across the United States, including leading on due diligence, FERC and state regulatory approvals, and deal document negotiations.

Professional Highlights

Honors & Awards

  • Recognized by The Legal 500 U.S., Energy: Renewable/Alternative Power, 2022, 2024
  • Recognized in The Best Lawyers in America guide, Litigation – Environmental, 2011–2020; Environmental Law, 2011–2025; Energy Law, Energy Regulatory Law, 2021–2025
  • Recognized in Who's Who Legal: Environment, 2016

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  • More Honors & Awards
    • Recognized in The Legal 500 U.S., Energy: Renewable/Alternative Power, 2022, 2024, 2025
    • Recognized in The Best Lawyers in America guide, Litigation—Environmental, 2011–2022; Environmental Law, 20112025; Energy Law, Energy Regulatory Law
    • Recognized in Who’s Who Legal, 2011
    • Recognized in Who’s Who Legal: Environment, 2016
    • Recognized by Chambers USA – America’s Leading Business Lawyers guide, Environment Law, 2011
    • Recognized by Chambers USA Guide to Leading Lawyers, Leaders in their Field, 2009, 2010
    • Recognized in International Who’s Who of Environment Lawyers, 2009
  • Memberships
    • Section, Division and Forum Coordination of the American Bar Association Section of Environment, Energy and Resources, Chair of the Special Committee, 2014, 2015
    • American Bar Association, Task Force on Policy and Coordination within Environment, Energy and Resource Law Section, Co-Chair, 2016–2018
    • American Bar Association, Standing Committee on Environmental Law, 20082011; Acting Chair, 2011
    • American Bar Association, Business Law Section Committee on the Environment, Energy & Natural Resources, Past Chair
    • Rebuilding Together Hartford, Inc., Past President
    • Edison Electric Institute Legal Committee, Associate Member
  • External Publications
    • FERC Chairman Chides PJM over Preemption Dispute on Regional Transmission Project, Holland & Knight Alert, April 22, 2025
    • Trump Executive Order Requires FERC, Other Agencies to Add Sunset Rule into Regulations, Holland & Knight Alert, April 15, 2025
    • Executive Order Strengthens the Reliability and Security of the U.S. Electric Grid, Holland & Knight Alert, April 14, 2025
    • FERC Takes Action on Co-Located Load in PJM, Holland & Knight Alert, February 26, 2025
    • First Look: FERC Discusses Co-Location of Large Loads, Holland & Knight Alert, November 7, 2024
    • Whats Next for the Regulatory Landscape Post-Chevron?, Holland & Knight Alert, July 2, 2024
    • New York Drafts Policy for Evaluating Permitting Impacts on Disadvantaged Communities, Holland & Knight Alert, October 11, 2023
    • In Blow to Renewables, Ninth Circuit Mostly Upholds FERCs PURPA Reforms, Holland & Knight Energy and Natural Resources Blog, September 7, 2023
    • FERC Requires Transmission Providers to File Extreme Weather Assessments, Holland & Knight Energy and Natural Resources Blog, June 23, 2023
    • FERC Approves New Cybersecurity Standards for Low-Impact Electric Assets, Holland & Knight Energy and Natural Resources Blog, March 17, 2023
    • Supreme Court Limits Power of EPA, Regulatory Agencies for Greenhouse Gas Emissions, Holland & Knight Alert, June 30, 2022
    • FERC Proposes Major Reforms to Generator Interconnection Process, Holland & Knight Energy and Natural Resources Blog, June 22, 2022
    • New York State Announces Nation-Leading Offshore Wind Investments, Pratt’s Energy Law Report, May 2022
    • New York State Announces Nation-Leading Offshore Wind Investments, Holland & Knight Alert, January 11, 2022
    • Holland & Knights Israel Practice Newsletter: Summer 2021, Holland & Knight Newsletter, August 24, 2021
    • Supreme Court Upholds Interstate Pipeline Eminent Domain Powers Over State Immunity, Holland & Knight Energy and Natural Resources Blog, July 2, 2021
    • New Federal Energy Regulatory Commission Rules on Market-Based Rates Coming Soon, Holland & Knight Energy and Natural Resources Blog, July 1, 2021
    • FERC to Natural Gas Pipeline Industry: What About Environmental Justice?, Holland & Knight Energy and Natural Resources Blog, February 25, 2021
    • Energy Customers Call for Grid Decarbonization and Increased Access to Wholesale Electricity Markets, Holland & Knight Energy and Natural Resources Blog, January 27, 2021
    • Monumental Offshore Wind Solicitations, Multiport Strategy Requirement and Millions in Public-Private Funding, Holland & Knight Energy and Natural Resources Blog, September 30, 2020
    • Holland & Knight's Energy and Natural Resources Quarterly Newsletter: Summer 2020, July 21, 2020
    • Department of Energy Issues Request for Information to Understand and Protect Bulk Power System, Holland & Knight Energy and Natural Resources Blog, July 13, 2020
    • Treasury Department to Extend Renewable Tax Credit Safe Harbor Deadlines, Holland & Knight Energy and Natural Resources Blog, May 8, 2020
    • Securing the U.S. Power Grid: President and Commerce Department Sound the Alarm, Holland & Knight Alert, May 6, 2020
    • New York Offers Guidance on Essential Energy Businesses During COVID-19 Pandemic, Holland & Knight Energy and Natural Resources Blog, April 1, 2020
    • House Democratic Climate Proposals Series: National Climate Program, Holland & Knight Energy and Natural Resources Blog, March 2, 2020
    • IRS Sheds New Light on the Solar Tax Credits, Leaves Energy Storage in the Dark, Pratt’s Energy Law Report, January 2019
    • IRS Sheds New Light on Solar Tax Credits, Leaves Energy Storage in the Dark, Holland & Knight Energy and Natural Resources Blog, September 7, 2018
    • FERC Opens Notice of Inquiry for Review of Natural Gas Pipeline Policies, Holland & Knight Alert, April 26, 2018
    • NY Issues Offshore Wind Master Plan, 2,400 MW to be Procured, Holland & Knight Energy and Natural Resources Blog, January 31, 2018
    • CT Creates New Brownfields Program, Adopts Brownfields Tax Credit, Holland & Knight Energy and Natural Resources Blog, October 30, 2017
    • DOE’s Grid Resiliency Pricing Rule Offers Hope for Nearly Extinct Coal, Nuclear Plants, Holland & Knight Energy and Natural Resources Blog, October 10, 2017
    • Second Circuit Rejects Constitutional Attack Against Connecticut Renewables Bids, Holland & Knight Energy and Natural Resources Blog, July 10, 2017
    • IL Agency Launches Major Support for Solar and Wind Energy, Holland & Knight Energy and Natural Resources Blog, June 7, 2017
    • In Trump Era, States Take Lead on Social Cost of Carbon, Law360, May 8, 2017
    • Colorado Utilities Commission Requires Consideration of Social Cost of Carbon, Holland & Knight Energy and Natural Resources Blog, May 2, 2017
    • Laws Of Energy Economics Present Reality for New Administration: Gas Is Cheaper Than Coal, Pratt’s Energy Law Report, March 2017
    • FERC Moderates NYISO Rule Impacting NY-Supported Demand Response, Holland & Knight Energy and Natural Resources Blog, February 8, 2017
    • Second Circuit Court Rules EPA’s Water Transfers Rule Allowed Under Chevron, Holland & Knight Energy and Natural Resources Blog, February 6, 2017
    • Trump Orders Expedited Environmental Reviews for High Priority Projects, Holland & Knight Energy and Natural Resources Blog, January 26, 2017
    • CT Supreme Court Adopts Narrow View of State Environmental “Actions,” Holland & Knight Energy and Natural Resources Blog, January 18, 2017
    • State Utility Commission Lacks Rate-Setting Authority over Retail Electric Supplier, Holland & Knight Energy and Natural Resources Blog, January 13, 2017
    • States and Private Sector Continue to Make Clean Energy Progress, Holland & Knight Energy and Natural Resources Blog, January 6, 2017
    • Laws of Energy Economics Present Reality for New Administration: Gas is Cheaper Than Coal, Holland & Knight Energy and Natural Resources Blog, January 3, 2017
    • Federal Electricity Policy Under the Trump Administration, Holland & Knight Alert, December 7, 2016
    • FERC Proposes Market Changes for Electricity Storage, Distributed Energy Resources, Holland & Knight Alert, December 6, 2016
    • BLM Issues Final Rule Streamlining Renewables on Public Lands, Holland & Knight Alert, November 14, 2016
    • Supreme Court Confirms State Limits on Wholesale Power Generation, Holland & Knight Alert, April 19, 2016
    • Supreme Court Walks Energy Policy Tightrope as it Addresses Federalism and States’ Rights, ABA SEER Trends, March 10, 2016
    • SCOTUS Hears Third Energy Policy Case: Federalism vs. States’ Rights, Electric Light & Power, February 26, 2016
    • Supreme Court: FERC Can Regulate Programs Directly Impacting the Wholesale Power Market, Holland & Knight Alert, January 29, 2016
    • Before Rolling Blackouts Begin: Briefing Boards on Cyber Attacks That Target and Degrade the Grid, William Mitchell Law Review, 2014
    • By Executive Order: Delivery of Cyber Intelligence Imparts Cyber Responsibilities, IEEE Security & Privacy, March/April 2013
    • Legal Duties to Avert, Mitigate and Recover from Cyber Attacks on the Grid, January 25, 2013
    • Solar Energy Project Development Issues: Preliminary Considerations, Practical Law Company, December 2012
    • Understanding Renewable Energy: Solar, Practical Law Company, December 2012
    • Searching for Swap Regulation Relief Under Dodd-Frank, Law360, September 20, 2012
    • Understanding Renewable Energy: Solar, Practical Law Company, September 10, 2012
    • Dodd-Frank Rules Clarify Relief from Swap Regulation for Certain Energy, Emission and Other Commodity Swaps, Holland & Knight Alert, September 5, 2012
    • Massachusetts Senate Passes Bill on Competitively Priced Electricity in the Commonwealth, April 23, 2012
    • Connecticut’s Energy Legislation: A Technology-Neutral Approach, Holland & Knight Alert, July 7, 2011
    • Supreme Court Rejects Federal Nuisance Claim for Greenhouse Gas Emissions, Holland & Knight Alert, June 21, 2011
    • Renewable Energy Opportunities and Environmental Challenges, Environmental and Energy Business Law Reporter, Summer 2011
    • Environmental Disclosures After Sarbanes-Oxley, The Practical Lawyer, June 2004
    • When Is the Parent Company Liable?, Business Law Today, November/December 2002
  • Speaking Engagements
    • Financing the Energy Transition amid New Regulatory Uncertainty, New York Energy Forum, September 17, 2024
    • Projects & Money, Infocast, January 17–19, 2024
    • ESG: Legal Disclosure Requirements and Regulations, Green Financing Series: Part 2, November 4, 2021
    • Practical Solutions to Manage PFAS Risks: A Webinar for Buyers, Sellers, Owners and Operators, Holland & Knight Program, June 8, 2021
    • ESG: Calculating Carbon Emissions for Financiers and Investor Assessment and Reporting, Green Financing Series: Part 1, April 28, 2021
    • Wind and Solar Energy Projects: Structuring EPC Agreements, Strafford Webinar, February 2, 2021
    • Structuring Solar PV Agreements: Negotiating Real Estate Entitlements and Offtake Agreements, Strafford CLE Webinar, March 18, 2020
    • Law Seminars International Renewable Energy in New England Conference, March 12–13, 2020
    • Joint Ventures in Renewable Energy Projects: Structure Options, Transferability, Allocation of Liability, Tax Equity and More, Strafford CLE Webinar, December 3, 2019
    • Wind and Solar Energy Projects: Structuring EPC Agreements, Unique Issues in Wind and Solar PV Construction Contracts, Including Guarantees and Warranties, November 20, 2019
    • Dominica and St. Vincent: Different Paths to the Geothermal Finish Line, 11th Caribbean Renewable Energy Forum, October 16–18, 2019
    • Nontraditional Offtake Strategies for Renewable Energy, NextEra CLE Event, August 27, 2019
    • Nontraditional Offtake Strategies for Renewable Energy: Avoiding Landmines in Contract Structuring and Financing, Strafford CLE Webinar, July 16, 2019
    • Intro to the Three Themes of Modern Energy Regulation (Role of Regulation; Federalism; Transition to Clean Energy), Holland & Knight Webinar, May 1, 2019
    • Offshore Wind Development: Legal and Business Insights into the First Projects in the U.S., Edison Electric Institute Spring Legal Conference, April 10, 2019
    • Latin America Series – Renewable Energy: An Investment In the Future, Holland & Knight Webinar, February 19, 2019
    • Structuring Solar PV Agreements: Negotiating Real Estate Entitlements and Offtake Agreements, Strafford Webinar, October 31, 2018
    • Overview of Regulatory Issues Associated with Renewable Energy Facilities, Lawline, April 24, 2018
    • Renewable Energy Projects: Structuring REC Purchase and Sale Agreement, Interconnection Agreement, Strafford Webinar, April 5, 2018
    • Solar Energy Projects: Structuring EPC Agreements – Unique Issues in Solar PV EPCs, Performance Guarantees and Defect Warranties, Strafford Webinar, November 28, 2017
    • The Not-So-Bright Line of FERC’s Jurisdiction, NECRA’s 2016 G&T Legal Seminar, November 3, 2016
    • Renewable Energy Projects: Structuring REC Purchase and Sale Agreement, Interconnection Agreement, Strafford Webinar, October 13, 2016
    • Annual Review of Hot Topics in Environmental and Energy Law, 2016 American Bar Association Annual Meeting, August 4–9, 2016

Education

  • J.D., Quinnipiac University School of Law, 1993

    B.S., Fairfield University, 1986

Admissions

  • New York

    Connecticut

    Florida

Courts

  • U.S. District Court for the District of Connecticut

    U.S. Court of Appeals for the Second Circuit

    Supreme Court of the United States