Carol J. Holahan

Co-Chair, Energy & Climate Practice Group
Carol Holahan is a partner in Foley Hoag's Energy & Climate practice. She advises large, competitive regional generators and other participants in the wholesale and retail competitive electricity markets on regional policy initiatives, changing environmental regulations, decommissioning and sale of plants, and matters pending before the Federal Energy Regulatory Commission.

In addition to concentrating on traditional fossil fuel generation, Carol’s practice includes renewable energy resources such as large solar storage and biomass and has significant experience in the NEPOOL stakeholder process. She also has considerable experience with matters involving legal challenges to new or existing laws and regulations, environmental permitting, facility siting and assessment or limitations of liability as a result of the sale or retirement of generating facilities.

Prior to joining to Foley Hoag, Carol was the Senior Director of Government Affairs at Dynegy Inc., the largest generator in New England and one of the largest power producers in the country prior to its 2018 merger with Vistra Energy. In this capacity, she developed and led Dynegy’s policy advocacy in the Northeast at the state and federal levels, and provided regulatory and government affairs support on energy and environmental issues affecting Dynegy’s wholesale and retail activities within the region. Before that, Carol served as Director of Government Affairs for the New England Power Generators Association (NEPGA), representing competitive power producers before state policy makers, regulators and infrastructure siting boards.

In addition to spending nearly a decade in private practice, Carol served more than 12 years as the Director of the Office of Legislative Services in New Hampshire, the non-partisan bill drafting and research office of the state’s 424-member legislature.


  • Suffolk University Law School, J.D., magna cum laude
  • Georgetown University, B.S

Bar and Court Admissions

  • Massachusetts
  • New Hampshire
  • U.S. Supreme Court


  • Mediated an urgent interconnection dispute on behalf of the owner of distributed generation resources, obtaining authorization to interconnect in time to avoid significant financial consequences. 
  • Advised a home solar, battery storage and energy services company client on regulatory, policy and wholesale electricity market issues and helped it secure an historic bid to deliver home solar and batteries as a capacity resource in ISO-NE’s Forward Capacity Auction, for the capacity commitment period June 1, 2022- May 31, 2023. The company’s participation in New England’s capacity market is the first time in the country that home solar and battery storage has directly participated alongside traditional generation resources in a wholesale capacity auction.
  • Represented intervenors in a proceeding before the Massachusetts Department of Public Utilities where important issues decided by the Department relating to electric vehicle (“EV”) expansion in the Commonwealth. The Department ultimately struck down the utility’s request both to expand significantly its EV program and to own and operate EV infrastructure.
  • Represented a competitive power producer in a proceeding before the Federal Energy Regulatory Commission opposing the price-suppressive aspects of a competitor’s cost-of-service agreement.
  • Represented a biomass generator before the New Hampshire Public Utilities Commission relative to an amendment to a power purchase agreement necessitated by a change in law.

  • Senior Director of Government Affairs, Dynegy Inc.
  • Director of Government Affairs, New England Power Generators Association, Inc.
  • Director, Office of Legislative Services, State of New Hampshire
  • Assistant Commissioner, Department of Administrative Services, State of New Hampshire
  • Law Clerk to Hon. Joseph R. Nolan, Massachusetts Supreme Judicial Court


  • "Massachusetts’ New Clean Energy Bill: Heavy On Storage, Light On Solar," Solar Industry and North American Windpower online publications (August 14, 2018)
  • "Constitutional and Legislative Considerations in the Administrative Rulemaking Process" (detailed summary of administrative and legislative process and state agency adjudicative hearings, prepared for a continuing legal education program sponsored by the New Hampshire Bar Association)
  • "Appeals from Administrative Agencies" (detailed summary of New Hampshire law relating to appeals under New Hampshire’s Administrative Procedures Act and by writ of certiorari, prepared for a continuing legal education program sponsored by the New Hampshire Bar Association)
  • "History of Legal Aid in the United States," 18 ABA-related Education, vol. 16, at 6 (with R. J. Steiner, 1994)
  • Note, "Private Sector Drug Testing: Availability of State Statutory Remedies for Aggrieved Employees," 21 Suffolk University Law Review 1067 (1987)

Honors & Involvement

  • Suffolk University Law Review
  • Northeast Energy and Commerce Association (NECA): Energy Diversity and Inclusion Committee 
  • Former board member, Northeast Energy and Commerce Association (NECA)
  • Former Chair, American Diabetes Association, NH Chapter
  • Former Chair, New Hampshire Bar Association Telecommunications, Energy and Utilities Law Section
  • Member, New England Women in Energy and the Environment

Speaking Engagements

  • 2021 Legislative Update Webinar, Northeast Energy & Commerce Association, October 20, 2021
  • Putting the Pieces Together for Successful Project Development: Overview of the Components of a Coherent Overall Strategy, Renewable Energy in New England Conference, September 25, 2020 
  • Effectively Engaging (DER) Stakeholders in Utility Grid Modernization Plan Development, Solar and Energy Storage Northeast Forum, February 19, 2020 
  • New England Energy Summit, December 2, 2019
  • New Hampshire Energy Summit, September 23, 2019
  • Power Magazine podcast, February 2019
  • New Hampshire Energy Summit, September 24, 2018
  • New England Energy and Commerce Association event, September 13, 2018
  • Exploring the Diversity of Potential Regional Energy Projects, EBC Energy Resources Program, March 18, 2016 
  • New Hampshire Annual Energy Summit, October 5, 2015
  • Zoning and Land Use Issues for Wireless Telecommunications Facilities: The Interplay of Federal, State and Local Law, Real Estate Bar of Massachusetts (REBA) 2015 Spring Conference, May 4, 2015
  • The Evolving Energy Landscape, Suffolk University Law School Center for Advanced Legal Studies, April 17, 2014
  • Administrative and Legislative Process and State Agency Adjudicative Hearings, NH Bar Association CLE, April 9, 2014