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About Sarah

Sarah Rafie counsels clients regarding compliance matters before the Federal Energy Regulatory Commission (FERC), Environmental Protection Agency (EPA), and other federal and state agencies.  She also advises clients on a variety of regulatory, commercial, and transactional matters related to the development of oil and gas pipelines.  Additionally, Sarah’s practice includes representing clients participating in the federal rulemaking process. 

Before joining Bracewell, Sarah served as a judicial intern to Judge Jennifer W. Elrod of the U.S. Court of Appeals for the Fifth Circuit in Houston, and as an appellate intern in the U.S. Attorney's Office for the Western District of Missouri. While in law school, Sarah worked as a research assistant for Professor Doug Laycock and was a member of his team for the religious liberty case Holt v. Hobbs, which won a unanimous victory at the U.S. Supreme Court. During her first year of law school, Sarah was the recipient of the Bracewell LLP Best Argument Award for outstanding oral advocacy.


Recent Notable Matters

Industrial trade associations — assisted with drafting comments on various EPA policy and regulatory initiatives under the Clean Water Act, Clean Air Act, and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund)

Publications and Speeches

"EPA Hazardous Air Pollutant Standards Risk And Technology Reviews: Tight Deadlines and (Some) DC Circuit Guidance," Environmental Quarterly, Summer 2017 edition.

"What the SEC is Seeking in Additional Event Disclosures," The Bond Buyer, March 9, 2017.



University of Virginia School of Law,
Baylor University,
summa cum laude

Bar Admissions

District of Columbia


Phi Beta Kappa
Women's Council on Energy and the Environment
Women's Energy Network
Energy Bar Association




FERC Annual Enforcement Update

FERC Annual Enforcement Update On November 16, 2017, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) released the Office of Enforcement’s (“OE”) annual report on enforcement activities (“ Annual Report ”) for fiscal year 2017 (“FY 2017”). Although the report, which covers activities from October 1, 2016 through September 30, 2017, merely reflects the activities and views of enforcement staff and is not necessarily representative of the views of the Commission or any Commissioner, the Annual Report can provide useful insights into compliance issues faced by market...

Barclays Market Manipulation Case Settles for $105 Million, What We Learned and What’s Next?

After more than four years of litigation in federal district court, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) yesterday issued an order approving a $105 million settlement resolving allegations that Barclays Bank PLC and certain of its traders (“Barclays”) participated in a scheme to manipulate western energy markets. The settlement, which reflects a significant reduction from the penalty sought by FERC, comes on the heels of the federal court granting one of the four individual defendant’s Motion for Judgment on the Pleadings based on the action being time-barred...

Statute of Limitations Bars FERC Penalty in Preeminent Market Manipulation Case

On Friday, the U.S. District Court for the Eastern District of California handed the Federal Energy Regulatory Commission (“FERC” or “Commission”) a significant defeat by concluding that FERC’s action against a former trader of Barclays Bank PLC accused of participating in a scheme to manipulate western energy markets [1] was barred by the statute of limitations. For now, the related allegations against Barclays, which is facing a $435 million civil penalty plus $34.9 million in disgorgement, and against three other traders remain intact. However, this dismissal, which comes on the heels of...

New Commission Approves City Power Manipulation Settlement

Yesterday, the Federal Energy Regulatory Commission (FERC) issued an order approving a settlement agreement between FERC’s Office of Enforcement and City Power Marketing, LLC, and its owner, K. Stephen Tsingas (together, City Power). The order resolves the Commission’s claims that City Power violated FERC’s anti-manipulation rule and its rule requiring truthful communications with the Commission. Without admitting or denying the allegations, Tsingas agreed to pay a $1.42M civil penalty and $1.3M in disgorgement, and City Power must pay a $9M civil penalty. FERC initially had sought a civil...

FERC Staff Issues New Guidelines on Cultural Resources

August 7, 2017

On July 31, 2017, the Federal Energy Regulatory Commission (“FERC”) staff issued new Guidelines for Reporting on Cultural Resources Investigations for Natural Gas Projects. The new guidelines include changes of potential interest and significance to developers (“project sponsors”). In addition to changes in the organization of reports and documents, the guidelines define more detailed expectations for project sponsors, particularly concerning engagement with tribes. It remains to be seen whether the changes lead to improved dialogue with tribes on cultural resources, or more divergence in...

FERC Technical Conference: Developments in Natural Gas Index Liquidity and Transparency

On Thursday, June 29, 2017, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) held a technical conference on the liquidity and transparency of natural gas price indices. The conference consisted of three discussion panels with panelists from various price reporting agencies (“PRAs”), trade associations, academia, energy companies, and other stakeholders. [1] There was general consensus among the panelists on a number of issues including general confidence in the indices, the importance of encouraging more price reporting, the need for a stronger safe harbor for price...

U.S. Supreme Court: Disgorgement Subject to Five-Year Statute of Limitations

The United States Supreme Court this week unanimously held that the five-year statute of limitations established in 28 U.S.C. §2462 applies to disgorgement in Securities and Exchange Commission (SEC) enforcement proceedings. The Court in Charles Kokesh v. Securities and Exchange Commission concluded that the SEC’s use of disgorgement amounts to a penalty and thus is subject to the five year statute of limitations. [1] The decision in Kokesh represents a further practical limitation on the SEC’s remedial power and could have implications for other agency actions, including the Federal Energy...

Another Win for Respondents’ Rights: District Court Opines on the Scope of De Novo Review

On March 8, 2017, the U.S. District Court for the Eastern District of California issued an order affirming that ETRACOM LLC and its owner (the “Respondents”) are entitled to a full trial on the merits and discovery rights in an action brought by the Federal Energy Regulatory Commission (“FERC” or the “Commission”) seeking to enforce an order assessing civil penalties against the Respondents for alleged market manipulation in the California energy market. The primary issue at stake was the meaning of the Federal Power Act’s (“FPA”) reference to “ de novo review” in a civil action brought by...

Navigating Unchartered Waters: FERC Provides Additional Guidance Through the Delegation of Additional Authority to FERC Staff for the Non-Quorum Period

In recent weeks, there has been much speculation over what actions the Federal Energy Regulatory Commission (“FERC” or the “Commission”) would take to ensure continuity of operations following the departure of Commissioner Norman Bay. Under the Department of Energy Organization Act, the Commission is required to have a quorum of three commissioners “for the transaction of business.” Because Commissioner Bay’s departure leaves only two FERC commissioners, many have questioned whether FERC would effectively cease to function until such time as the Trump administration is able to fill commission...



University of Virginia School of Law
Journal of Law and Politics
Editorial Board Member
U.S. Attorney's Office for the Western District of Missouri
Appellate Intern
Judge Jennifer W. Elrod, U.S. Court of Appeals for the Fifth Circuit
Judicial Intern
University of Virginia School of Law
Bracewell LLP Best First-Year Oral Argument Award
Texas Undergraduate Moot Court Association
Regional First-Place Speaker
American Moot Court Association, Ranked in the top sixteen undergraduate moot court teams in the nation