Deborah Carpentier is a senior counsel in Crowell & Moring's Washington, D.C. office, where she practices in the firm's Energy Group. She focuses primarily on federal regulatory and transactional energy issues for electric utilities and natural gas companies in matters before the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC). This representation includes advising clients on regulatory and reliability-related compliance programs, NERC Reliability Standards, market-based rates and other regulatory approvals, standards of conduct and other affiliate relationship issues, market manipulation, the terms and conditions of service of electric utilities and gas pipelines, electric and gas rate litigation, natural gas pipeline certificate proceedings, and hydroelectric regulatory matters.
Deborah advises clients on all aspects of the NERC Reliability Standards, including NERC registration issues, preparing for compliance audits or investigations by Regional Entities, and preparing self-reports and mitigation plans. She has represented clients in multiple settlement negotiations with NERC and Regional Entities on a variety of enforcement matters.
In addition, Deborah has conducted and documented gap analyses of the NERC and FERC compliance programs, resulting in recommendations for improving compliance functions and remedying areas of noncompliance. She has also developed comprehensive compliance programs to ensure that companies remain compliant with FERC and NERC requirements and has provided training on these programs to ensure that they are implemented effectively.
Deborah has represented energy companies before FERC's Office of Enforcement in relation to self-reports of violations of the Federal Power Act (FPA), the Natural Gas Act (NGA) and FERC's rules implementing those statutes, including market-based rates, the requirement to obtain prior approval of disposition of public utility facilities and the prohibition of buy-sell arrangements for natural gas.
Deborah also advises clients on regulatory matters arising in their operations or commercial transactions involving the development and operation of generation projects, including power purchase agreements, operating agreements, and purchase and sale agreement. These regulatory matters include transfers of public utility facilities, market-based rates, exempt wholesale generators, interlocking positions, capacity release rules, and other issues involving the FPA, Public Utility Holding Company Act of 2005, NGA, Natural Gas Policy Act of 1978, Interstate Commerce Act as it relates to oil and products pipelines, and the Public Utility Regulatory Policies Act of 1978.
Deborah is a member of the Energy Bar Association and the American Bar Association. At The George Washington University Law School, she served as executive managing editor of the George Washington Journal of International Law and Economics, was a member of the Moot Court Board, and was a Dean's Fellow.
Education
- University of Maryland, College Park, B.A. (1988)
- The George Washington University Law School, J.D. (1992) with honors
Affiliations
Admitted to practice: District of Columbia, Maryland
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