Collier-Brown, Carrie

Carrie Collier-Brown

Senior Counsel



Carrie Collier-Brown is a regulatory and administrative litigation attorney with a broad range of experience in the areas of energy, water and telecommunications utilities and general administrative law. Carrie advises clients before the Public Utility Commission of Texas (PUC), Railroad Commission of Texas, Federal Energy Regulatory Commission (FERC) and Texas state courts.

In her PUC practice, Carrie represents electric utilities, electric cooperatives, water utilities, generators, retail electric providers and other clients in a broad range of regulatory and administrative litigation matters, including rate applications, mergers and acquisitions, Certificate of Convenience and Necessity (CCN) proceedings, generator interconnections, certification and registration, regulatory compliance and enforcement and policy rulemakings.

On the federal energy level, Carrie has advised electric utilities and generation companies on compliance with Qualifying Facility (QF) certification, NERC reliability standards, competition-related issues in RTO and ISO markets and Open Access Transmission Tariffs compliance matters at FERC.

In the area of gas utility regulation, Carrie represents midstream pipeline companies and natural gas utilities in permitting and compliance matters before the Railroad Commission of Texas (the state's principal oil and gas regulatory authority).

Carrie has also advised clients on Smart Grid policy, wireless licenses, and pole attachment issues at the Federal Communications Commission.

She has had extensive experience with the implementation of Senate Bill 7, the 1999 legislation introducing retail competition in the Texas electric market. Prior to attending law school, Carrie was on staff with the PUC, where she led rulemaking proceedings on retail customer protections and drafted rules for energy efficiency, CCNs, renewable energy labeling and the "Price to Beat" rate for the competitive electricity market in Texas.

Representative Experience

Carrie's experience includes the representation of:

Public Utility Commission of Texas

  • Trade association of competitive retail electric providers in policy rulemakings and contested proceedings at the PUC
  • Fiber infrastructure company in certification for a Service Provider Certificate of Operating Authority
  • Buyers and sellers of generating facilities on Texas regulatory and ERCOT market issues
  • Non-ERCOT electric utility in base rate cases, Energy Efficiency Cost Recovery Factor (EECRF) cases, Transmission Cost Recovery Factor (TCRF) cases and fuel reconciliation proceedings
  • Electric transmission utility in base rate case and CCN transfer proceedings
  • Water and waste water utility in rate case; Sale, Transfer, Merger applications; and advised company on rulemaking proceedings at the PUC
  • Electric utility's largest industrial customer in base rate case, TCRF and DCRF cases
  • The state's third-largest REP in a successful challenge to joint marketing between transmission and distribution utility and its affiliated competitive REP
  • The state's second-largest electric utility in appeals of municipal ordinances
  • Potential equity investors in proceeding to acquire the state's largest electric utility out of bankruptcy
  • Pipelines, landowners and developers in electric utility CCN proceedings
  • Electric utilities, electric cooperatives, REPs and generators in enforcement proceedings
  • Electric utility in rulemaking project to revise the standard Tariff for Retail Delivery Service
  • Renewable energy generators on transmission line interconnections

Railroad Commission of Texas

  • Natural gas utilities and pipelines in rate setting proceedings and regulatory matters
  • Multiple intrastate and interstate pipeline companies in permitting, compliance, pipeline safety and complaint matters

Federal Energy Regulatory Commission

  • Electric utility in dispute regarding qualifying facilities
  • Investor-owned electric utility on compliance with FERC Order Nos. 888 and 890, including preparation and filing of compliance filings and revisions to Open Access Transmission Tariff (OATT)
  • A Midwest transmission owner on FERC compliance issues, focusing on transmission service and related FERC-jurisdictional agreements
  • Investor-owned utility on compliance with North American Electric Reliability Corporation (NERC) reliability standards
  • Two investor-owned utilities on transfer of control of FCC wireless licenses as part of merger application to FERC

Texas District Court and Third Court of Appeals

  • Electric utility in proceedings regarding qualifying facilities dispute
  • The state's third-largest REP in appeal of PUCT decision on joint marketing between transmission and distribution utility and its affiliated REP

Professional History

  • Senior Counsel, Locke Lord LLP, Austin, Texas
  • Government Relations, Austin Energy, Austin, Texas
  • Retail Market & Legislative Analyst, Public Utility Commission of Texas, Austin, Texas
  • Policy Analyst, House Research Organization, Texas House of Representatives, Austin, Texas

Professional Affiliations and Recognitions

  • Member, State Bar of Texas
  • Member, District of Columbia Bar
  • State Bar of Texas Public Utility Law Section
    • Council Member (2017-2019)
    • Treasurer (2020)
    • Chair-Elect (2021)
  • Member, Gulf Coast Power Association Empowering Women Committee, 2017-2018
  • Planning Committee, GCPA Empowering Women Leadership Conference, 2015-2017
  • Member, Texas Utility Lawyers