Kirk D. Rasmussen

Kirk Rasmussen advises private and public business organizations regarding state and federal regulatory matters. His practice covers the breadth of the administrative process, including contested case proceedings, compliance counseling, licensing matters, rulemakings, appeals of agency decisions, and the myriad issues associated with owning, operating, or transferring assets within a regulated market. His numerous clients have included some of the country’s largest electric generators, investor owned and public transmission and distribution utilities, retail electric providers, and large consumers of electricity.

Phone: ‭(512) 615-1203‬

Professional Background

Publications & Presentations

Professional & Community Activities

Professional Background


  • Represents a variety of private and public clients before the Public Utility Commission of Texas (PUCT), the Electric Reliability Council of Texas (ERCOT), the North American Electric Reliability Corporation (NERC), the Texas Reliability Entity (TRE), the Federal Energy Regulatory Commission (FERC), the Texas Department of Insurance (TDI), the Railroad Commission of Texas (RRC), the Texas Office of Consumer Credit Commissioner (OCCC), the Texas State Office of Administrative Hearings (SOAH), the Arkansas Public Service Commission (APSC), and other federal and state regulatory bodies
  • Represents clients in the sale, transfer, and merger of electric generation and utility assets
  • Negotiation of power purchase agreements 
  • Represents clients in all aspects of utility ratemaking proceedings
  • Represents clients in certificate of convenience and necessity (CCN) proceedings involving high-voltage transmission lines
  • Advises clients regarding compliance with agency regulations
  • Advises clients regarding development of alternative energy projects, including solar energy, biofuel, wind power, and energy storage projects
  • Advises clients regarding the development and implementation of smart-grid facilities
  • Advises clients regarding participation in ERCOT, including counseling regarding application and revision of the ERCOT Protocols and Operating Guides
  • Advises clients regarding registration and participation in NERC and compliance with NERC Reliability Standards
  • Advises clients regarding state and federal regulatory implications of energy transactions, including structuring issues
  • Advises clients regarding energy and utility legislation pending before the U.S. Congress, Texas Legislature, and other state legislative bodies
  • Advises clients on utility tariff issues, interconnections, and contributions in aid of construction (CIAC)
  • Represents clients in all aspects of administrative and regulatory proceedings, rulemakings, complaint actions, and licencing
  • Represents utility clients in Texas state court administrative appeals
  • Drafts and negotiates generation interconnections and associated agreements and consents between electric generators, transmission service providers, and financial institutions
  • Drafts and negotiates all manner of agreements for energy clients, including affiliate agreements
  • Represented Texas's largest generator of electricity, largest investor-owned and public transmission and distribution utilities, and largest retail electric providers
  • Represented municipally-owned utilities, retail electric providers, oil and gas exploration and production companies, public and private universities, and entities acquiring energy services
  • Represented developer of on-site energy generation and management systems
  • Represented the U.S. Department of Energy in connection with the licensing of its Yucca Mountain Project (geologic nuclear waste repository) by the U.S. Nuclear Regulatory Commission
  • Represented Texas’s largest independently owned title company and one of the largest credit services organization and credit access business in Texas

Awards & Recognitions

  • Board Certified in Administrative Law by the Texas Board of Legal Specialization
  • Texas Super Lawyers, Administrative Law, 2017, 2018, & 2019
  • Top Lawyers, Texas Monthly, 2018
  • Ranked: Chambers USA, Energy: State Regulatory & Litigation (Electricity) – Texas, 2018 & 2019
  • Lawyers of Distinction, Administrative Law, 2018
  • Texas Rising Star, Texas Monthly, 2010

Admitted to Practice

  • Texas


  • Duke University School of Law, Durham, North Carolina
    - J.D., 1999
    Duke Journal of Comparative & International Law, Executive Editor
    Duke Environmental Law & Policy Forum, Contributions Editor
  • Duke University, Durham, North Carolina
    - M.A., Environmental Science, 1999
  • Brigham Young University, Provo, Utah
    - B.S., Conservation Biology, 1996

Publications & Presentations

  • FERC and NERC Regulation in Texas, Texas Utility Lawyer Association Annual Meeting, 2011
  • Witness Skills, Burns & McDonnell Transmission Line Routing Seminar, 2011
  • ERCOT February 2011 Extreme Cold Weather Event: Counsel to a Generator’s Perspective, 4th Annual Power and Alternative Energy Law Conference, 2011
  • Regulatory Hurdles to Achieving a Smart Grid, 2nd Annual IEEE Green Technologies Conference, 2010
  • Regulatory Obstacles to Achieving a Smart Grid, Smart Grid America Forum, 2009
  • "How to Avoid Accidentally Becoming a Regulated Electric Utility in Texas" (Co-author), Texas Real Estate Business, 2006
  • "Who Will Play Poker in the Texas Saloon if the Sheriff Makes Everyone Play With Their Cards Face Up?: The Importance of Protecting Competitively Sensitive Information in the Restructured Texas Electric Market" (Co-author), Texas Tech University School of Law Administrative Law Journal, 2004

Professional & Community Activities

  • State Bar of Texas
    - Environmental & Natural Resources Section
    - Public Utility Law Section
  • Austin Bar Association
    - Administrative Law Section
  • Dallas Bar Association
  • American Bar Association
    - Administrative Law & Regulatory Practice Section
    - Environment, Energy, & Resources Section
    - Infrastructure & Regulated Industries Section
  • Eagle Scout
  • Boy Scouts of America, Friends of Scouting Campaign, White Buffalo District, Circle 10 Council Chairman, 2005–2006