Elizabeth B. Kohlhausen
Elizabeth focuses on federal and state regulation of crude oil, natural gas liquids, refined petroleum products and natural gas pipelines. Elizabeth has represented clients in complex rate litigation proceedings before the Federal Energy Regulatory Commission (FERC) and the California Public Utilities Commission (CPUC), and she also frequently provides advice to clients regarding pipelines subject to the jurisdiction of the Railroad Commission of Texas.
She is well-versed in the development of liquids pipeline projects and regularly counsels clients on regulatory matters affecting their development. She has extensive experience in preparing documentation related to these types of projects, including Transportation Services Agreements, tariffs, and prorationing policies, and she has also prepared and filed multiple Petitions for Declaratory Orders with FERC in support of these types of projects. In addition, Elizabeth has significant experience counseling clients on operational issues and liquid pipeline tariff modifications.
- Currently leading the litigation team in the Docket No. OR16-6 proceeding before FERC regarding complaints challenging SFPP’s East Line existing rates.
- Representing multiple liquids pipelines in various regulatory, contractual and operational matters related to the addition of new capacity.
- Represented, along with other CBL attorneys and California counsel, a cost-of-service rate proceeding before the CPUC related to intrastate transportation rates and defending against claims of carrier impudence
- Represented the Association of Oil Pipelines before FERC in a market-based rates proceeding
- Represented a major refined petroleum products system in protest proceedings at FERC regarding application of the FERC’s indexing methodology to the pipeline’s rates
- Assisted with the representation of owners of the largest crude oil pipeline in the United States in administrative litigation before FERC and the U.S. Court of Appeals for the D.C. Circuit
- Assisted with the representation of a major refined petroleum products pipeline system in implementing increased rates related to a large expansion project
- Assisted with the representation of a crude oil pipeline in implementing increased rates and in negotiation of a unanimous settlement of resulting protests
- Assisted with the successful representation of a crude oil pipeline against challenges to the reversal of a segment of its pipeline
Natural Gas Pipelines
- Assisted with the representation of multiple interstate natural gas pipelines in Natural Gas Act Section 4 rate proceedings at FERC
- Assisted with the representation of industry group in proceedings related to Order Nos. 712 and 712-A before FERC and the DC Circuit
Prior results do not guarantee a similar outcome.
- SFPP, L.P., Docket Nos. IS08-390, IS09-432, IS11-444, OR16-6
- Kinder Morgan Pony Express Pipeline LLC and Belle Fourche Pipeline Company, Docket No. OR12‑26
- CenterPoint Energy Bakken Crude Services, LLC, Docket No. OR13-21
- MarkWest Liberty Ethane Pipeline, L.L.C., Docket No. OR14-1
- Enable Bakken Crude Services, LLC, Docket No. OR14-24
- Palmetto Products Pipe Line LLC, Docket No. OR15-13
- NORCO Pipe Line Company, LLC, Docket No. OR15-27
- Enterprise TE Products Pipeline Company LLC, Docket No. OR15-35
- Buckeye Pipe Line Transportation LLC, Docket No. OR16-5
Education and Professional Background
- Prior to forming Caldwell Boudreaux Lefler PLLC, Elizabeth was an Attorney at Vinson & Elkins LLP (V&E) and a member of V&E’s liquids pipeline regulatory team for six years. Before joining V&E, Elizabeth practiced in the litigation group of another international law firm.
- University of Houston Law Center, J.D. magna cum laude, 2006 (Order of the Coif; Order of the Barons; Alumni Developments Editor, Houston Law Review)
- Louisiana Tech University, B.S. Accounting summa cum laude, 2002
- Admitted to practice: Texas, 2006; U.S. District Court for the Southern District of Texas; U.S. Court of Appeals for the District of Columbia Circuit
Activities and Affiliations
- Energy Bar Association;
- Houston Bar Association;
- Houston Volunteer Lawyers Program;
- Houston Young Lawyers Association
Publications and Presentations
- “Non-Rate Tariff Provisions” Annual Conference of the Association of Oil Pipelines (September 2016)
- “Federal Midstream Regulatory Update for Liquids Pipelines”, The Center for American and International Law, 4th Midstream Oil & Gas Law Conference (December 2015)
- “Non-Rate Tariff Provisions: Everything You Always Wanted to Know About Rules and Regulations,” Annual Conference of the Association of Oil Pipelines (September 2015 )
- “FERC Regulation of Liquids Pipelines – Current Rules and Emerging Trends,” EUCI CLE Presentation (October 2014)
- “Oil Gathering and NGL Dedications in Shale Plays: Unique Regulatory Issues and Solutions,” Annual Conference of The Association of Oil Pipelines (September 2014)
- “Regulatory and Commercial Issues in Shale Plays,” CLE Presentation at The Texas Journal of Oil, Gas & Energy Law’s 8th Annual Texas Energy Law Symposium, January 2013
- “The Evolution and Future of FERC NGL Pipeline Regulation,” CLE Presentation, December 2012
- “Oil & Gas Infrastructure Development in Domestic Shale Plays: Regulatory and Commercial Issues,” CLE Presentation, November 2012
- “Ethics Issues Associated With Using Temporary Legal Personnel, Marking Documents as Privileged, and Entering into Joint Defense Arrangements,” Annual Conference of The Association of Oil Pipelines (September 2009)
- “Ethanol Pipeline Jurisdiction,” Energy Bar Association, Oil Pipeline Regulation Committee (April 2009)
- “What Lies Ahead for ERISA’s Preemption Doctrine after a Judicial Call to Action in Aetna Health Inc. v. Davila,” 43 Hous. L. Rev. 125, 2006