Thomas’s principal area of practice is energy regulation and litigation. He advises natural gas and oil pipelines, electric utilities, and energy market participants in rate, certificate, and enforcement proceedings before the Federal Energy Regulatory Commission and the Commodity Futures Trading Commission.
Representing affiliated multi-national energy companies and individuals in defending FERC allegations of natural gas market manipulation
Representing a major refined products (i.e., gasoline, diesel, jet fuel) pipeline at a three-month hearing on eighteen consolidated complaints alleging that its indexed and market-based rates were no longer just and reasonable under the Interstate Commerce Act
Representing a natural gas pipeline and winning dismissal on jurisdictional grounds of a complaint regarding unpaid reservation charges during the February 2021 Texas cold weather event
Representing a natural gas pipeline in consolidated rate-case proceedings under Section 4 and Section 5 of the Natural Gas Act
Obtaining an order from FERC declaring that it lacks jurisdiction over a small-scale liquified natural gas facility that would export LNG in containers via ocean-going cargo vessels
Advising an electric utility on its annual formula rate update and responding to formal challenges to the update
Conducting an internal investigation of trading activities and responding to multiple rounds of CFTC inquiries on behalf of a commodity pool operator
Education
Admissions
Client Alerts
FERC Adopts PPI-FG Minus 0.55% Oil Pipeline Index for 2026-2031
On April 24, 2026, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued its final rule in Docket No. RM26-6-000 …
April 29, 2026
April 29, 2026 • 7-minute read
Client Alerts
On November 20, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued four significant orders addressing crude oil, petroleum products, and natural gas liquids pipelines (collectively, “oil pipelines”) matters: (1) a Notice of Proposed Rulemaking (“NOPR”) for the Five-Year Review of the Oil Pipeline Index (“2026 Index NOPR”) proposing an index level of Producer Price Index for Finished Goods (“PPI-FG”) minus 1.42% for the period (July 1, 2026 to June 30, 2031); (2) an Order denying rehearing and granting oil pipelines remedial relief related to the reinstated oil pipeline index for the period March 1, 2022 to September 17, 2024; (3) an order withdrawing the supplemental notice of proposed rulemaking that proposed to amend the index level to PPI-FG minus 0.21% on a prospective basis from July 1, 2025 until June 30, 2026; and (4) an order denying Airlines for America and the National Propane Gas Association’s petition requesting that the Commission initiate a rulemaking to establish affiliate standards of conduct regulations for oil pipelines.
November 26, 2025 • V&E Energy Update
November 26, 2025 • 7-minute read
Client Alerts
FERC Settles Decade-Old Enforcement Allegations
In 2016, a new play called Hamilton was dominating Broadway, Pokémon Go was all the rage, and the Summer Olympics were held in Rio.
January 14, 2025 • V&E Energy Update
January 14, 2025 • 4-minute read
Client Alerts
The Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Office of Enforcement (“Enforcement”) continues to focus on enforcing its duty of candor rules, with a recent action resulting in a $6.6 million civil penalty and a requirement to file at least one compliance monitoring report to settle alleged violations of 18 C.F.R. § 35.41(b) of the Commission’s regulations.
January 7, 2025 • V&E Energy Update
January 7, 2025 • 2-minute read
Client Alerts
On October 17, 2024, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued a Supplemental Notice of Proposed Rulemaking (“Supplemental NOPR”) that proposes a reduction to the currently effective index by one percent.
October 18, 2024 • V&E Energy Update
October 18, 2024 • 3-minute read
Awards & Rankings
The Best Lawyers in America has named 124 Vinson & Elkins lawyers in its “Best Lawyers” category in the 2024 edition. Additionally, 87 Vinson & Elkins attorneys have been named in the Ones to Watch category, which recognizes lawyers with 5-10 years’ experience. Some individuals are listed in more than one practice area, giving the firm a total of 308 rankings.
August 21, 2023
August 21, 2023 • 2-minute read
Firm News
Vinson & Elkins Expands Energy Regulatory Practice with Addition of Prominent Litigation Team
Vinson & Elkins has added a team of eight litigators to its Energy Regulatory practice. Led by partner William Scherman, the team includes partners Jeffrey Jakubiak and Jason Fleischer, counsel Laura Swett, Jennifer Mansh and Thomas Kirby, senior counsel Judge John Dring and associate Phillip Washburn.
February 21, 2023
February 21, 2023 • 3-minute read
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