Reagan Lutter

Associate

Energy Regulation

Reagan Lutter

Overview

Reagan’s principal area of practice is energy regulation. Her practice includes counseling clients on a variety of regulatory and transactional matters involving the Federal Energy Regulatory Commission.

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Experience

  • A BlackRock Diversified Infrastructure fund and a Morgan Stanley Infrastructure Partners fund in their $1.14 billion joint acquisition of the Portland Natural Gas Transmission System from TC Energy Corporation and its partner Northern New England Investment Company, Inc., a subsidiary of Énergir L.P.

  • Endeavor Energy Resources in its $26 billion merger with Diamondback Energy

  • Voyager Midstream, a portfolio company of Pearl Energy, in connection with its acquisition of East Texas gathering and processing assets from Phillips 66

  • Assisted with reviewing and providing comments on an interstate crude oil pipeline’s environmental impact statement

  • Assist Vitol with negotiating the sale of several onshore wind projects

  • Assisted with drafting a sequestration services agreement for carbon sequestration

  • Assisted with negotiating and drafting a power purchase agreement for wholesale sales of power from a client’s waste-heat-to-power generation project

  • Represented tax equity investors in passive interest analyses and the drafting of consent rights pursuant to FERC precedent

  • Represented natural gas pipelines, storage facilities, and producers in FERC regulatory matters, including filing and prosecution of certificate applications, pipeline rate and tariff matters, and rulemaking proceedings

  • Represented interstate natural gas pipelines and storage providers in the preparation and prosecution of general rates case under Section 4 of the Natural Gas Act before the FERC

  • Represented power generator in FERC investigation regarding allegations of market manipulation and tariff violations in Northeastern energy markets

  • Assisted shippers and project sponsors in negotiation and development of intrastate and NGPA Section 311 rates and terms and conditions of service on intrastate natural gas pipelines in Texas and Louisiana

Capabilities

Credentials

Education

  • University of Houston Law Center, J.D., summa cum laude, 2021 (Salutatorian; Order of the Coif; Editor in Chief, Houston Law Review)
  • University of Oklahoma, B.A., Environmental Sustainability, summa cum laude, 2016

Admissions

  • Texas
Insights

Client Alerts

FERC States that It Clarifies Applicability of SFV Rate Design Methodology to NGPA Section 311 Pipelines

In a significant order addressing the rate design and regulatory compliance obligations of intrastate pipelines providing interstate transportation service under Section 311 of the Natural Gas Policy Act of 1978 (“NGPA”), the Federal Energy Regulatory Commission (“FERC” or the “Commission”) has clarified the application of the Straight-Fixed Variable (“SFV”) rate design methodology and minimum rate requirements applicable to pipelines offering service under NGPA Section 311.

December 22, 2025 • V&E Energy Update

December 22, 2025 • 5-minute read

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