The Firm’s natural gas practice is extensive, both in terms of its scope and depth. The Firm has been involved in a broad variety of regulatory proceedings before the Federal Energy Regulatory Commission (FERC) over the past thirty years. Examples of such experience include the following:
- advising clients regarding matters related to the interstate transportation of natural gas, including FERC’s regulation of pipeline rates and services;
- advising clients regarding the use of interstate transportation capacity, including asset management arrangements;
- representing U.S., Canadian and Mexican-based producers and/or marketers of natural gas in administrative litigation before FERC, especially pipeline rate cases;
- representing various clients in FERC rulemaking and generic policy proceedings;
- securing market-based rate authority for interstate natural gas storage facilities;
- securing certificates of public convenience and necessity for new and expanded interstate natural gas storage facilities and pipelines;
- securing FERC authorization to construct and operate liquefied natural gas (LNG) import and export terminals;
- advising interstate natural gas storage facilities and pipelines on compliance matters, including the adoption of FERC tariffs and reporting obligations;
- advising intrastate natural gas storage facilities and pipelines providing interstate service under Section 311 of the Natural Gas Policy Act on compliance matters, including the adoption of Statements of Operating Conditions and reporting obligations;
- representing clients in audits, self-reports of potential violations, and public and non-public investigations before FERC’s Office of Enforcement and the Commodity Futures Trading Commission;
- conducting annual compliance training for natural gas market participants; and
- representing clients in appellate cases before the U.S. Courts of Appeals.
The Firm also serves as counsel to the owners and developers of LNG projects located in Alaska and Texas as well as natural gas and LNG importers and exporters, advising them regarding infrastructure, transactions, rates, services, compliance and/or environmental regulatory matters. The Firm has secured authorizations for clients from the Department of Energy to export LNG and natural gas to both free trade and non-free trade countries.