Overview

Debra Ann Palmer brings clarity to complex energy industry and regulatory matters. Clients come to Deb seeking solutions to complicated issues. They leave her office with distinct vision of how to achieve their goals.

Deb understands the interrelationship between operational, business, and regulatory concerns faced by the energy industry. She has cultivated a deep knowledge in these areas, earning a reputation as an authority in the planning, operating, financial, regulatory and reliability issues facing the rapidly changing natural gas and electric industries. This in-depth knowledge is critical to her effective, efficient representation of industry participants.

Deb has successfully represented gas and electric utilities, natural gas pipelines, electric generators, natural gas processors and others on a wide variety of matters before the Federal Energy Regulatory Commission (FERC) as well as federal and state courts for over 25 years.

Deb’s not-so-secret weapon is her ability to transform the arcane into the compelling. Clients – and colleagues – turn to her to craft incisive arguments communicating her clients’ positions. Her ability to understand  regulators’ goals and present her clients’ interests accordingly has helped her become a leading advocate for energy firms across the United States. 

  • Experience

    • Deb has been closely involved in efforts by the Federal Energy Regulatory Commission and various state agencies to increase coordination between the gas and electric industries in order to ensure reliable service. She has also assisted clients in efforts to increase natural gas pipeline infrastructure in New England. These efforts have included review of precedent agreements for the construction of new pipeline facilities, including facilities to transport natural gas from the Marcellus Shale region to New England.
    • Deb regularly assists clients in investigations pursued by FERC’s Office of Enforcement (OE). She has guided numerous successful settlement negotiations with OE, and helped clients respond to data requests. She also drafts internal compliance manuals and training materials, conducts on-site training sessions regarding FERC rules and requirements and counsels energy industry clients regarding compliance with Commodity Futures Trading Commission (CFTC) regulations adopted to implement the Dodd-Frank Act.
    • Deb has a wide array of experience representing gas and electric utilities in various rate, tariff, and certificate matters before FERC. She represented a local distribution company (LDC) with respect to its efforts to resolve safety and gas quality concerns related to liquefied natural gas. She has also represented electric utilities in various transmission matters, including proceedings involving the development of formula rates. She has drafted market-based rate tariffs and assisted clients in the negotiation of contracts to purchase and sell electricity.
  • Credentials

    Education

    • Case Western Reserve University School of Law, J.D., 1987, magna cum laude
      Order of the Coif
    • Tufts University, B.A., 1984, magna cum laude

    Bar Admissions

    • District of Columbia
    • U.S. Court of Appeals for the Fourth Circuit
    • U.S. Court of Appeals for the Sixth Circuit
    • U.S. Court of Appeals for the Ninth Circuit
    • U.S. Court of Appeals for the Eleventh Circuit
    • U.S. Court of Appeals for the District of Columbia Circuit
    • U.S. District Court for the District of Columbia

        Professional Memberships

        Energy Bar Association

        Board of Directors (May 2006-May 2009)

        Programs and Meetings Committee

        Past Chair

         

        Women’s Council on Energy and the Environment

      • Insights

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        Blog Post

        FERC Prevails Again in Order No. 1000 Appellate Proceedings

        Schiff Hardin Energy & Environmental Law Adviser

        Blog Post

        FERC Issues Fast-Start Resources NOPR

        Schiff Hardin Energy & Environmental Law Adviser

        Blog Post
        Blog Post

        FERC Issues NOPR on Info Collection, Rescinds Previous Iterations of Rule

        Schiff Hardin Energy & Environmental Law Adviser

        Blog Post

        CFTC and EPA to Share Renewable Fuel Standard Data

        Schiff Hardin Energy & Environmental Law Adviser

        Blog Post

        Supreme Court Issues Ruling on FERC Order No. 745

        Schiff Hardin Energy & Environmental Law Adviser

        Blog Post
        Blog Post

        FERC Order: Supply AMAs Are Exempt from Prohibition on Buy-Sells

        Schiff Hardin Energy & Environmental Law Adviser

        Trending Legal Issue

        Speeches & Presentations

        Deb is a frequent contributor to Schiff Hardin’s Energy and Environmental Law Adviser and a frequent speaker on current topics in the energy industry:

        • “Gas-Electric Coordination,” (co-presenter) Sixth Annual Energy Markets Conference, American Gas Association, New York, N.Y. (Oct. 3, 2013)
        • “FERC and the CFTC: Sharing the Worlds of Market Manipulation, Regulation and Compliance,” (co-presenter) American Gas Association Legal Forum, Newport, R.I. (Jul. 15, 2013)
        • “Rate Implications of a Changing Gas Supply Future," American Gas Association Energy Market Regulation Conference, Fort Worth, Texas (Sep. 22, 2011)

      Energy and Environmental Law Adviser

      FERC Prevails Again in Order No. 1000 Appellate Proceedings

      On April 19, 2017, the U.S. Court of Appeals for the D.C. Circuit unanimously upheld the Federal Energy Regulatory Commission’s (FERC) implementation of Order No. 1000 with respect to ISO-New England (ISO-NE). The D.C. Circuit had previously upheld the legality of the order itself in 2014, and the Seventh Circuit upheld FERC’s implementation of Midcontinent...… Continue Reading

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