Leading Counsel for Power Projects, Energy Markets & Complex Trading Agreements
I advise clients at the intersection of energy law, project development, and capital markets—particularly in connection with power projects, natural gas assets, and structured trading arrangements that support long-term resiliency and growth.
My experience spans the full energy value chain, including:
- EEI and NAESB master agreements for physical power and gas
- ISDA Master Agreements and Credit Support Annexes (CSAs) for financial and commodity hedging
- Firm and interruptible gas transport, storage, and balancing arrangements
- Virtual and sleeved PPAs, tolling agreements, and merchant hedging strategies
- RNG offtake agreements, environmental attribute structures, RIN/LCFS monetization, and shipping
- ISO/RTO market participation and financial transmission rights (FTRs)
I have led more than $8 billion in complex transactions, including acquisitions of power generation portfolios, natural gas rights, energy marketers, and infrastructure assets. I support data center developers, power marketers, industrial offtakers, RNG developers, and others navigating evolving power and gas markets.
In addition to project-based counsel, I serve as outside general counsel to energy companies, a global technology company, and a social media news platform, providing ongoing legal support in commercial transactions, regulatory compliance, corporate governance, data privacy, and licensing across diverse industries.
Executive-Level Insight Across Energy, Gas, and Infrastructure Markets
As General Counsel and Commercial General Manager for a major North American energy company, I oversaw one of the continent’s largest power and natural gas marketing operations. Responsibilities included:
- Leading M&A and post-merger integration of multi-jurisdictional assets
- Structuring and negotiating gas shipping and supply agreements across pipelines and hubs
- Managing risk and credit strategy across structured trades and bilateral portfolios
- Building operational frameworks for ISO/RTO participation and load supply contracts
This blend of legal and commercial leadership equips me to provide business-minded legal advice tailored to the needs of infrastructure developers, market participants, and innovation-focused enterprises.
Energy Compliance, Trading Governance & Regulatory Strategy
I’ve advised clients across a broad range of regulatory and market structures, including:
- Structuring internal compliance programs for trading desks, asset operations, and control rooms
- Developing credit and margining policies for hedge counterparties under ISDA and CSA terms
- Addressing obligations related to environmental markets, renewable fuel standards, and market-based decarbonization programs
- Supporting corporate governance, trading risk mitigation, and market access strategy in energy, RNG, and digital infrastructure contexts
ISDA Master Agreement & CSA Transition Post-Acquisition
Client Type: Acquiring Energy Company
Issue: Following a major acquisition, multiple ISDA Master Agreements and Credit Support Annexes needed to be assigned or re-papered under the acquiring entity’s name, requiring harmonization with its credit rating and internal risk management framework
Approach: Led the legal workstream coordinating with trading counterparties, credit teams, and risk management to transition ISDA and CSA agreements; negotiated amendments and novations to align collateral terms, margining thresholds, and legal entities with the acquiring company’s policies and credit profile
Result: Successfully migrated all ISDA/CSA relationships to the acquiring entity without disruption to trading operations, while ensuring compliance with internal credit risk controls and preserving trading continuity
Natural Gas Shipping & Transport Optimization
Client Type: U.S.-Based Power Generator
Issue: Required legal support to secure long-term, flexible natural gas transport and supply arrangements across multiple regions to ensure reliable fuel delivery for dispatchable generation assets
Approach: Led the drafting and negotiation of firm and interruptible transportation agreements, NAESB base contracts for gas supply, and associated balancing provisions across several interstate pipeline systems; aligned contractual terms with operational dispatch needs, credit policies, and index-based pricing mechanisms
Result: Delivered a comprehensive legal framework supporting secure and cost-effective gas delivery, enhancing reliability, reducing imbalance exposure, and enabling economic dispatch optimization across the client’s generation portfolio
Acquisition and Integration of Power & Gas Marketing Business
Client Type: North American Energy Company
Issue: Strategic expansion through the acquisition of a major natural gas and electricity marketing business with operations across the U.S. and Canada
Approach: Served as lead counsel and led a large, cross-functional legal, regulatory, and compliance team through all phases of the transaction. Oversaw legal structuring, diligence, regulatory approvals, and risk allocation, while coordinating integration of wholesale and retail trading contracts, credit frameworks, compliance programs, and licensing portfolios. Worked closely with senior executives and operational teams to ensure continuity of trading and market-facing operations across multiple jurisdictions
Result: Successfully executed and integrated the acquisition, establishing one of the largest independent power and gas marketing platforms in North America, with unified legal infrastructure, expanded market access, and enhanced regulatory and risk controls
Acquisition of Natural Gas Rights and Infrastructure
Client Type: Energy Holding Company
Issue: Upstream and midstream growth through acquisition of large-scale natural gas assets in Western Canada
Approach: Served as lead counsel on the acquisition of over 1 million acres of natural gas rights and multiple gas processing facilities. Directed all legal aspects of the transaction, including asset diligence, title review, regulatory and environmental risk assessment, transaction structuring, and negotiation of definitive agreements. Coordinated closely with cross-border commercial, operations, and finance teams to align closing conditions and integration strategy
Result: Successfully closed a complex cross-border acquisition, securing long-term natural gas supply, expanding midstream capabilities, and enabling continued trading and portfolio optimization across North American markets
Outside General Counsel – Technology, Energy & Media
Clients: Global SaaS Company | Energy Companies | Digital News & Media Startup
Issues: Ongoing legal needs spanning commercial transactions, regulatory compliance, employment matters, IP protection, branding, and content licensing
Approach: Serve as trusted outside general counsel, providing day-to-day legal support and strategic advice across a range of operational and corporate matters. Draft and negotiate software licensing agreements, energy service contracts, media and contributor agreements, and vendor terms; advise on employment issues, compliance frameworks, data privacy, and risk mitigation strategies
Result: Delivered a scalable and business-aligned legal foundation that supports rapid growth, international expansion, brand protection, and operational resilience
Education
- William Mitchell College of Law, J.D., cum laude – Law Review Editor
- Hamline University, B.A. History and Legal Studies, summa cum laude, Phi Beta Kappa
Bar Admissions
- Minnesota
- Texas
- Lead counsel for the creation of a 501(c)(3) nonprofit supporting ALS research
- Board Member, Changing Young Children’s Lives Through Education, Houston
- Pro bono services for disaster relief, nonprofit training, and legal aid clinics
- North Star Lawyer for pro bono services to Minnesota’s communities
"Bray is an exceptional partner in structured energy deals. He brings a deep understanding of power market dynamics, trading risk, and commercial strategy." – Energy Consultant
“Bray is the best commercial lawyer I have ever worked with – he understands the economics of a deal and negotiates with mastery.” – Energy Company CEO
"Bray navigated a complex M&A process with clarity, attention to detail, and a business-minded approach. A tremendous legal and strategic partner." – Private Equity Client
- CEO’s Platinum Award for Excellence in ERCOT Nodal Market Implementation
- Pro Bono Award for Representation of Death Row Client
- Outstanding Business Partner Awards for Strategic Legal and Commercial Leadership
- Multi-Year Finalist, Best Corporate Counsel – Houston Business Journal
- Featured in Who’s Who in Energy – Houston, Dallas, and Pittsburgh
