Cases
Experience: Assisting an interstate natural gas pipeline in its successful bid to win FERC's first-ever approval of a tariff permitting the pipeline to reserve unused capacity on its system for use in low-cost expansion projects that otherwise would require a more time-consuming
more costly formal application for a certificate of public convenience
necessity.
Helping two natural gas pipeline companies evaluate jurisdictional, regulatory,
environmental issues related to making bids to construct new onshore
offshore pipelines to export natural gas from the United States to Mexico.
Representing a group of transmission-owning electric utilities in FERC litigation of complaints that seek to lower the utilities' base return on equity allowance by more than $400 million per year.
Representing a group of transmission-owning utilities in FERC litigation of the liability of transmission owners that withdrew from an RTO for a portion of the costs of multi-billion dollar transmission projects included in the RTO's regional transmission expansion plan.
Advising
representing Transcontinental Gas Pipe Line Company, LLC, in several applications for authorization of interstate natural gas pipeline expansions involving terms of a capacity lease, air quality compliance requirements,
other economic
environmental issues.
Represented Transcontinental Gas Pipe Line Company, LLC, in several FERC rate proceedings from 1995 through 2012. Such cases typically involve well over100 parties. Assisted in obtaining settlements of most issues
achieved successful litigation outcomes on others.
Represented Kern River Gas Transmission Company, another interstate natural gas pipeline, in a successful effort to convince FERC to adopt a new approach, favorable to the company, to determining pipelines' allowed rates of return on equity. Obtained in the same proceeding what is believed to be FERC's first-ever approval of pipeline transportation rates based on a 100% equity capital structure with no offsetting adjustment of the company's allowed rate of return.
Assisted an electric utility client with a FERC/NERC enforcement investigation,
advised a natural gas pipeline client in FERC compliance audits that presented potential enforcement issues. Both engagements were resolved on favorable terms through settlements.
Represented an RTO in multiple proceedings culminating in FERC's approval of revisions to the client's tariffs
market rules. These have included provisions governing market participation
operational performance of dem
response resources, pricing of cross-border energy transactions,
terms
conditions for interconnection of new generation
merchant transmission facilities, among others.
Represented a l
owner in negotiating
documenting a long-term lease for construction of a merchant, natural gas-fired electric generating plant.
Represented an electric generation
transmission cooperative in negotiating agreements for a joint venture to develop an additional generating unit at an existing plant solely owned by the client.
Assisted a private equity investment fund with its evaluation of a potential acquisition of an interstate pipeline.