Midstream

Overview

Steptoe & Johnson’s regulatory attorneys assist clients with natural gas, NGLs, and electric matters involving regulation by the Federal Energy Regulatory Commission (FERC), by state public utility regulatory commissions, and in unregulated businesses in various producing basins.

Firm attorneys have worked in government and as in-house counsel for Fortune 500 energy companies; have counseled clients on federal and state regulation of natural gas utilities, gathering and processing facilities, and intrastate and interstate pipelines and storage facilities; and have developed and implemented FERC compliance programs. This real-world experience provides the perspective needed to create effective, value-added solutions for clients.

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Representative Experience

State Regulatory Experience

Defended a major natural gas producer from claims that its pipeline should be regulated
Represented clients regarding certificates of public convenience and necessity, utility rate cases, affiliated transactions cases, purchases and sales of public utilities, defense of customer complaints, agency rule-making, and territorial disputes
Represented purchasers in state regulatory, real property, and environmental due diligence in planned acquisition of natural gas local distribution company
Assisted numerous clients in obtaining regulatory approval for financings, construction projects, and agreements with affiliates

FERC Experience

Represented and counseled gas pipelines in general and limited-rate case proceedings, technical conferences, rule-making, tariff, service, expansion, abandonment, and construction certificate matters
Advised clients on gathering intrastate and interstate facility classifications and distinctions, and FERC jurisdiction over facilities, rates, or services by intrastate pipelines and local distribution companies
Represented FERC-regulated companies on numerous FERC enforcement matters, including extensive negotiation experience on matters involving significant penalties
Developed, implemented, and managed a FERC compliance program for interstate natural gas pipelines and public utilities
Represented public utilities on rulemaking, RTO, inter-connection, and rate matters
Assisted FERC-regulated hydroelectric facilities with post-licensing compliance matters

Midstream Experience

Counseled midstream natural gas businesses and interstate natural gas pipelines on federal and state regulation of facilities, rates, services, safety, and eminent domain matters
Represented and counseled pipelines and electric transmission utilities regarding easements, rights-of-way, and condemnation issues and proceedings in state and federal courts
Negotiated and drafted natural gas gathering and transportation agreements
Counseled clients on extent of regulation over natural gas liquids (NGLs) pipelines
Assisted in structuring transactions to minimize regulation and achieve business objectives