Deborah A. Carpentier

Deborah advises clients on regulatory matters arising in their operations or commercial transactions involving the development and operation of generation projects, including market-based rate issues and approvals, transfers of public utility facilities, obtaining and maintaining exempt wholesale generator status, market manipulation, NERC reliability standards, interlocking positions, capacity release rules, and other issues involving the Federal Power Act, Public Utility Holding Company Act of 2005, Public Utility Regulatory Policies Act of 1978, Natural Gas Act, Natural Gas Policy Act of 1978, and Interstate Commerce Act as they relate to oil and products pipelines.

Deborah represents energy companies before FERC’s Office of Enforcement in relation to self-reports of violations of the FPA, NGA, and FERC’s rules implementing those statutes, including market-based rates, the requirement to obtain prior approval of the disposition of public utility facilities, and the prohibition of buy/sell arrangements for natural gas.

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.