Deborah R. Repman

Deborah R. Repman
Deborah R. Repman


P: (713) 357-6241
F: (713) 357-6775
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Deborah’s principal area of practice is regulatory compliance with federal and state law governing the transportation of crude oil, petroleum products and natural gas liquids by pipeline. Deborah has experience in administrative litigation before both the Federal Energy Regulatory Commission (FERC) and the California Public Utilities Commission (CPUC), including complaint proceedings that challenge a pipeline’s existing rates and protests to cost-of-service rate filings. Deborah also has extensive experience in developing and negotiating transportation services agreements and related open season documents to support greenfield and brownfield liquids pipeline projects. She is also well versed in tariff-related matters, including drafting complex tariff provisions for liquids pipelines.

Representative Experience

Liquids Pipelines

  • Managed the discovery matters related to a liquids pipeline proceeding at FERC and the CPUC
  • Leading the litigation team in a crude oil pipeline proceeding before the CPUC regarding protests challenging the pipeline’s proposed rate increases
  • Leading a litigation team in defending a crude oil pipeline’s application for market-based ratemaking authority
  • Assisted in the development of multiple market-based ratemaking applications filed by crude oil, petroleum products, and natural gas liquids pipelines
  • Assisting in the representation of a major petroleum products pipeline in challenges to the pipeline’s jurisdictional status
  • Preparation of pre-filed testimony and pre-hearing/post-hearing briefs at FERC and the CPUC
  • Leading teams in the preparation and drafting of transportation services agreements, open season materials, throughput and deficiency agreements, tariffs, prorationing policies and similar documents associated with greenfield and brownfield liquids pipelines
  • Drafting petitions for declaratory orders before FERC related to new and expansion liquids pipeline projects, and securing FERC’s approval of the proposed terms and rate structures for such projects
  • Drafting and filing liquids pipeline tariffs with the FERC and state agencies
  • Developing and implementing complicated tariff provisions and rate structures in tariffs filings at the FERC and the RRC
  • Drafting and negotiating capacity lease arrangements involving liquids pipelines
  • Counseling clients on a wide array of regulatory matters concerning liquids pipelines, including cost allocation mechanisms, rate structure proposals, proposed terms related to new pipeline projects, connection policies
  • Developing compliance programs for liquids pipelines aimed at ensuring compliance with FERC’s requirements
  • Conducting audits of a liquids pipeline’s books and records to confirm compliance with FERC’s rules and regulations

Natural Gas Pipelines

  • Assisted in the negotiation and drafting of natural gas gathering and processing agreements and lease connection agreements associated with an interstate natural gas pipeline
  • Assisted in providing guidance and analysis concerning the regulatory requirements for interstate and intrastate natural gas pipelines
  • Assisted in the preparation and drafting of negotiated rate agreements and interstate natural gas tariffs

Prior results do not guarantee a similar outcome.


  • Pro Bono representation of a Sudanese woman seeking asylum in the United States
Education and Professional Background
  • Prior to joining Caldwell Boudreaux Lefler PLLC, Deborah was an Attorney at Vinson & Elkins LLP (V&E) and a member of V&E’s liquids pipeline regulatory team since her graduation from law school in 2010.
  • South Texas College of Law, J.D. magna cum laude, 2010
  • The University of Texas, B.S., 2005
  • Admitted to practice: Texas, 2010; U.S. Court of Appeals for the District of Columbia Circuit
Activities and Affiliations
  • Energy Bar Association
  • Vice-Chair/Chair of Oil & Liquids Pipeline Committee (2016-2017)