Carrie Collier-Brown is Senior Counsel in the Austin office of Locke Lord LLP where she is a regulatory and administrative litigation attorney in the areas of public utilities, energy, water, and general administrative law. Carrie serves clients before the Public Utility Commission of Texas (PUC), Railroad Commission of Texas, and the Federal Energy Regulatory Commission (FERC).
In her PUC practice, Carrie represents electric utilities, water utilities, renewable energy generators, retail electric providers, and other clients in a broad range of matters, including rate applications, administrative litigation, regulatory compliance, enforcement, Certificate of Convenience and Necessity (CCN) proceedings, and rulemakings.
On the federal energy level, Carrie has advised electric utilities and generation companies on compliance with 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, compliance, rate-setting and litigation matters before the Railroad Commission of Texas (the state’s principal oil and gas regulatory authority).
Carrie has also advised utility 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 a policy analyst for 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 ExperiencePublic Utility Commission of Texas
Railroad Commission of Texas
- Represented 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
- Represented electric transmission utility in base rate case
- Represented water and waste water utility in rate case; Sale, Transfer, Merger applications; and advised company on rulemaking proceedings at the PUC
- Represented electric utility’s largest industrial customer in base rate case, TCRF and DCRF cases
- Represented the state’s third largest REP in challenge to joint marketing between transmission and distribution utility and its affiliated REP
- Represented the state’s second largest electric utility in appeals of municipal ordinances
- Represented potential equity investors in proceeding to acquire the state’s largest electric utility out of bankruptcy
- Represented pipelines and developers in electric utility CCN proceedings
- Represented electric utilities, REPs and generators in enforcement proceedings
- Represented electric utility in rulemaking project to revise the standard Tariff for Retail Delivery Service
- Represented renewable energy generators on transmission line interconnection disputes
Federal Energy Regulatory Commission
- Represent natural gas utilities and pipelines in rate setting proceedings and regulatory matters
- Represent multiple intra and interstate pipeline companies in permitting, compliance, pipeline safety, and complaint matters
Texas District Court and Third Court of Appeals
- Represented electric utility in dispute regarding qualifying facilities
- Advised 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)
- Represented a Midwest transmission owner on FERC compliance issues, focusing on transmission service and related FERC-jurisdictional agreements
- Advised investor-owned utility on compliance with North American Electric Reliability Corporation (NERC) reliability standards
- Provided counsel and represented two investor-owned utilities on transfer of control of FCC wireless licenses as part of merger application to FERC
- Represented electric utility in proceedings regarding qualifying facilities dispute
- Represented the state’s third largest REP in appeal of PUCT decision on joint marketing between transmission and distribution utility and its affiliated REP
- 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
- Council Member, State Bar of Texas Public Utility Law Section, 2017-2018
- Member, Gulf Coast Power Association Empowering Women Committee, 2017-2018
- Planning Committee, GCPA Empowering Women Leadership Conference, 2015-2017
- Member, Texas Utility Lawyers