Crude Oil and Liquids
The Firm represents and advises clients on matters involving the interstate carriage by pipeline of crude oil and liquids under the Interstate Commerce Act (ICA).
Some of our more recent representative matters include:
- advising a number of Canadian and U.S.-based shippers on matters involving the transportation of crude oil and liquids;
- representing crude oil and liquids producers and/or marketers in the U.S. and Canada in Federal Energy Regulatory Commission (FERC) proceedings, including pipeline rate cases, pipeline tariff proceedings, many of which involve prorationing, and rulemaking proceedings;
- advising clients on the development of new or expanded crude oil pipelines, including drafting open season documents, pro forma transportation service agreements, pro forma tariffs, and prorationing policies;
- drafting and filing petitions for declaratory order with FERC to obtain prior regulatory approval of the proposed rate structures, terms and conditions of service, and prorationing policies for new or expanded crude oil pipelines developed by clients;
- advising and representing clients on crude oil and liquids pipeline compliance matters and tariff filings;
- drafting and filing petitions with FERC in order to obtain clients temporary waivers of the tariff filing and reporting requirements applicable to interstate crude oil and liquids pipelines under the ICA; and
- conducting training on FERC’s regulation of crude oil and liquid pipelines.
In addition to matters that are directly subject to FERC’s jurisdiction, the Firm also has extensive experience in related non-jurisdictional matters.