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Gibbs, Kirstin E.
Kirstin E. Gibbs
P: +1.202.828.5878
F: +1.800.404.3970
P: +1.713.223.2300

Karen Bishop


Kirstin Gibbs represents  pipelines, producers, traders, marketers, utilities, and end-users in matters related to natural gas and oil transportation and storage. She advises clients on Federal Energy Regulatory Commission (FERC) compliance and enforcement issues, as well as rate, policy, and legislative matters involving natural gas and oil companies. Kirstin also provides  transactional advice to major oil and natural gas producers and pipeline companies located and operating in the U.S., including in the Gulf of Mexico.

She counsels global and U.S.-based clients in connection with liquefied natural gas (LNG) issues including supply, siting, maritime issues, as well as obtaining import and export authorizations from the U.S. Department of Energy (DOE). In addition, Kirstin has experience addressing unique commercial and regulatory issues affecting LNG regasification and liquefaction terminals and related pipeline capacity.

Representative Matters

FERC Regulatory Compliance and Enforcement
Serving as lead counsel in a FERC enforcement matter involving a local distribution company.

Serving as lead counsel to develop and implement FERC compliance programs and best practices, as well as training programs for a wide variety of natural gas trading and marketing clients, local distribution companies, natural gas pipelines, and end users.

Serving as lead counsel responsible for internal audits and compliance investigations related to the FERC regulations applicable to natural gas trading and marketing companies, LNG and local distribution companies and oil pipeline companies.

Serving as the lead counsel conducting an internal investigation of two interstate pipelines’ compliance with FERC Standards of Conduct requirements.

Providing ongoing advice on compliance with FERC regulatory requirements that impact natural gas and oil companies.

Serving as lead counsel on behalf of energy companies seeking authorization from the U.S. Department of Energy (DOE) to export liquefied natural gas to free trade agreement (FTA) and non-FTA countries.

Providing transactional advice related to negotiating agreements for access to liquefaction capacity and capabilities at U.S. LNG export facilities.

Counseling a wide variety of energy companies on the application of FERC and DOE regulations to onshore and offshore U.S. liquefaction and LNG storage terminals.

Serving as lead regulatory counsel on behalf of an LNG importer with respect to ongoing negotiations of numerous capacity arrangements at the Cove Point Terminal and for all related implementation, rate and policy issues affecting capacity at the terminal as well as downstream natural gas transportation and storage.

Serving as regulatory counsel on behalf of several LNG importers for the analysis of all federal regulatory issues affecting LNG importation and natural gas matters, including Natural Gas Act Section 3 and 7 authorization and certificate issues for LNG terminals and downstream pipelines, regasification and pipeline capacity transfer issues, and other rate and policy issues.

Serving as regulatory counsel for securing DOE import authorization for several LNG importers.

Providing counsel to LNG importers in ongoing analysis of commercial, regulatory and policy developments affecting U.S. LNG terminals.

Serving as counsel analyzing shippers’ rights and obligations under an LNG terminal tariff and numerous settlement agreements.

Serving as lead regulatory counsel to an LNG importer and natural gas marketer in pipeline-specific natural gas interchangeability proceedings at FERC.

Serving as lead regulatory counsel to an LNG importer and providing advice on general FERC policy matters involving capacity release and natural gas price transparency issues.

Oil Pipeline Regulatory
Counseling clients on jurisdictional and other questions related to siting oil and gas pipelines on the Outer Continental Shelf and onshore.

Advising clients on compliance with the Interstate Commerce Act and the Outer Continental Shelf Lands Act requirements related to awarding capacity on new or expanded oil pipelines.

Providing guidance to clients regarding the applicability of open access and nondiscriminatory requirements for offshore oil pipelines.

Obtaining waiver of ICA regulations applicable to interstate oil pipeline located in North Dakota.

Counseling oil pipeline on tariff issues and filing tariff at FERC for approval.

Reviewing precedent agreements on behalf of shipper clients for new and expanded oil pipeline facilities in the United States and Canada.

Representing a shipper before FERC in a proceeding involving a diluent pipeline and providing commercial and transactional advice regarding the related Transportation Service Agreement and tariff provisions.

Advising clients regarding FERC ratemaking issues involving capacity reserved for committed and uncommitted shippers.

Publications and Speeches

"Regulatory Developments in North American LNG Export," Platts 14th Annual Liquefied Natural Gas Conference, February 2015

"Recent Regulatory and Environmental Challenges Impacting the Development of New Natural Gas Infrastructure," The Aspen Institute Forum on Global Energy, Economy and Security, July 2014

Speaker, "North American Exports Outlook North American Exports Outlook," Platts 13th Annual LNG Conference, February 2014

Co-author, "Environmental Roadblocks," Oil & Gas Financial Journal – Online, November 2013

Co-author,  "Do Regulatory Delays Mean the U.S. is Missing the Boat on LNG Exports?" Houston  Business Journal, October 2013

Speaker, "Liquefied Natural Gas Exports – Developments and Current Challenges," Bracewell & Giuliani 2013 Oil & Gas Regulatory Symposium, (October 9, 2013)

Speaker, "Natural Gas Infrastructure Projects – Environmental and Regulatory Challenges," AGA Legal Committee Forum, (July 14-16, 2013)

Speaker, "The State of LNG Exports," Bracewell & Giuliani 2012 Oil & Gas Regulatory Symposium, (March 1, 2012)

Speaker, "Regulators and Government Panel: Working With the Industry to Unleash the Potential of Shale Gas," and Co-Leader, "Shale Gas Legal and Regulatory Issues Master Class," World Shale Gas Conference and Exhibition (November 3-5, 2010)

Speaker, "Focus on Shale: Is Unconventional Gas Becoming Conventional?" LNG Americas Summit (March 16-18, 2010)

Speaker, "Best Practices for Creating a Compliance Program that Meets FERC Requirements," ACI’s 3rd Annual Energy Trading Compliance Conference (September 22-23, 2009)

Speaker, "Preparing for and Responding to Government Investigations and Audits," ACI’s 3rd Annual Energy Trading Compliance Conference (September 22–23, 2009)

Speaker, "On and Offshore LNG Regasification Terminals: Maximizing Potential," LNG New Orleans (April 27–29, 2009)


J.D., Catholic University of America, Columbus School of Law, 1997
B.A., LeMoyne College, 1990

Bar Admissions

District of Columbia
*Not licensed to practice in Texas


Public Utility, Communications and Transportation Law Section, American Bar Association
Energy Bar Association


Thomson Reuters, Washington, D.C. Super Lawyers, 2013-2015
Woodward/White, Inc., Best Lawyers, Energy Law, Oil & Gas Law, 2014-2016
Chambers & Partners, Chambers USA, Energy: Oil & Gas (Regulatory & Litigation), 2010-2015
Legalease, The Legal 500 United States, Energy: Regulatory, 2012, 2014-2015