Deborah A. Carpentier

Senior Counsel
Washington, D.C.
dcarpentier@crowell.com
Phone: +1 202.624.2857
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

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.


Affiliations

Admitted to practice: District of Columbia, Maryland



Highlights, News & Knowledge

Publications

  • "NERC's Enforcement Authority Weakened, Other Recent Developments," Natural Gas & Electricity (November 2014). Author: Deborah A. Carpentier.
  • "NERC Provides New Definition of Bulk Electric System," Natural Gas & Electricity (September 2014). Author: Deborah A. Carpentier.
  • "NERC & Enforcement Issues: Self-Reporting Routine Compliance Violations," Natural Gas & Electricity (July 2014). Author: Deborah A. Carpentier.
  • "NERC Gains in Vegetation Management, Cyber and Physical Security, and Reliability Assurance," Natural Gas & Electricity (May 2014). Author: Deborah A. Carpentier.
  • "NERC Provides Best Practices for Effective Procedures," Natural Gas & Electricity (March 2014). Author: Deborah A. Carpentier.
  • "NERC and FERC Attempt to Eliminate Reliability Gaps in Tie Lines," Natural Gas & Electricity 30/6, Wiley Periodicals (January 2014). Author: Deborah A. Carpentier.
  • "NERC's Quest for Steady-State Standards," Natural Gas and Electricity (November 2013). Author: Deborah A. Carpentier.
  • "NERC: Electric System is Adequately Reliable," Natural Gas and Electricity (August 2013). Author: Deborah A. Carpentier.
  • "NERC Followed in Canada," Natural Gas and Electricity (April 2013). Author: Deborah A. Carpentier.
  • "Eliminating Zero-Tolerance Enforcement," Natural Gas and Electricity (February 2013). Author: Deborah A. Carpentier.
  • "Sharing NERC Compliance Responsibilities Risky to Reliability," Natural Gas and Electricity (December 2012). Author: Deborah A. Carpentier.
  • "Tort Immunity for Cyber Attacks Through SAFETY Act," Natural Gas and Electricity (November 2012). Co-Author: Deborah A. Carpentier.
  • "Coming Into Compliance With Cyber Protection—A Legal Perspective," Natural Gas and Electricity (October 2012). Author: Deborah A. Carpentier.
  • "What is Missing From Your Compliance Program," Natural Gas and Electricity (July 2012). Author: Deborah A. Carpentier.
  • "Vexatious PRC-005," Natural Gas and Electricity (May 2012). Author: Deborah A. Carpentier.
  • "NERC Enforcement Needs Improvements," Natural Gas and Electricity (March 2012). Author: Deborah A. Carpentier.
  • "Should NERC Impose Winter Preparedness Requirements on Generators," Natural Gas and Electricity (January 2012). Author: Deborah A. Carpentier.
  • "NERC Rules Impose Major Requirements on O&M Contracts and M&As," Natural Gas and Electricity (November 2011). Author: Deborah A. Carpentier.
  • "Establishing a Culture of Compliance," Natural Gas and Electricity (September 2011). Author: Deborah A. Carpentier.
  • "Update to Last Month's 'All GOPs Are Not TOPs,'" Natural Gas and Electricity (August 2011). Author: Deborah A. Carpentier.
  • "All GOPs Are Not TOPs," Natural Gas and Electricity (July 2011). Author: Deborah A. Carpentier.
  • "Demonstrating Compliance with NERC Reliability Standards," Natural Gas and Electricity (April 2011). Author: Deborah A. Carpentier.
  • "Government Guidelines for Competitive Collaborations to Clarify Future Gas Ventures," Natural Gas (January 2000). Contributor: Deborah A. Carpentier.
  • "Antitrust: Growing Concern in Gas Industry," Natural Gas (November 1999). Contributor: Deborah A. Carpentier.
  • "Commission Stays Firm on Capacity Turnback, Reverses Contested Settlements," Natural Gas (October 1999). Co-Author: Deborah A. Carpentier.
  • "The Case for Reasonable Incentives to Promote Independent Transmission Companies," The Electricity Journal (August/September 1999). Co-Author: Deborah A. Carpentier.
  • "Many Questions about Approval of Settlements under Free Market," Natural Gas (March 1999). Co-Author: Deborah A. Carpentier.
  • "Commission Battles Capacity Turnback in Recent Case," Natural Gas Co-Author: Deborah A. Carpentier.

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