2024 Year in Review
We are grateful for the opportunities afforded us in 2024 to collaborate with our clients to achieve their regulatory goals . As we look ahead to 2025 , we ’ re excited about the new challenges we ’ ll tackle with our clients , continuing to build on our track record of success .
In 2024 , we proudly supported industry leaders such as Buckeye Partners , Colonial Pipeline , DT Midstream , Enbridge , Enterprise , Kinder Morgan , Pembina Pipeline , Phillips 66 , Tallgrass Energy , Targa Resources , TC Energy , and The Williams Companies , among many others . A key highlight for our group this year was the addition of Partner Michelle Boudreaux to our Houston office . Michelle is a respected leader of the oil and gas regulatory bar , and we ’ re excited to have her on our team .
Here is a summary of the work that kept us busy in 2024 :
1 . Natural Gas Pipeline Development
There is a well-publicized backlog of new natural gas pipeline projects to serve LNG export facilities , replace coal-fired generation , and meet the energy needs of new data centers around the United States . Together with colleagues in our environmental group , we worked with multiple clients across all phases of natural gas pipeline development . Our team negotiated precedent agreements , prepared open season materials , participated in FERC ’ s pre-filing process , filed certificate applications , and defended projects from landowner and environmental opposition at FERC and before appellate courts . We also advised on developments involving intrastate pipelines and Section 311 of the Natural Gas Policy Act , in addition to handling priornotice applications and related opposition .
2 . Natural Gas Pipeline Rate Cases
Our lawyers have extensive experience representing clients in natural gas pipeline rate proceedings . This year we represented clients in several natural gas pipeline rate cases , successfully navigating challenges to achieve settlements in both pre-filed and Section 4 applications . We also continued to advise clients on intrastate pipeline matters related to Section 311 rates .
3 . Oil Pipeline Rate Cases
This year involved extensive work on rates for liquids pipelines , both cost of service and index rates . In addition to successfully guiding clients through contested rate proceedings , we helped numerous clients navigate the complex compliance issues that arose from the DC Circuit ’ s decision regarding indexbased rates in Liquid Energy Pipeline Assoc . v . FERC , 109 F . 4th 543 ( D . C . Cir . 2024 ), and FERC ’ s follow-on orders addressing that decision .
4 . Natural Gas and Oil Pipeline Tariff Proceedings
We take pride in working with our clients to develop innovative services and tariff provisions to meet the ever-changing needs of their customers . Over the course of the year , we worked with numerous clients to address those needs through offerings of new pipeline services and the development of modified tariff provisions . When the proposed new services and tariff provisions were challenged at FERC , we successfully defended them .
5 . Liquids and CO2 Pipeline Development
This year our team members represented numerous clients in matters related to pipeline project development in the liquids and the energy transition spaces . On the liquids side , for example , we prepared the commercial and related agreements underpinning the planned development of new natural gas liquids pipeline projects , and provided regulatory advice regarding those projects . Also , we continue to deepen our involvement and expand our expertise in midstream projects at the forefront of the energy transition , representing clients developing new carbon capture , transportation , and / or sequestration projects and projects involving the production and transportation of biogas and renewable natural gas .
6 . Jurisdictional Issues
Questions regarding the jurisdictional reach of the Natural Gas Act , Natural Gas Policy Act , Interstate Commerce Act , and the Pipeline Safety Act continued to affect our clients and their pipeline assets in 2024 . As significant as any other issue impacting the development of new , or conversion of existing , energy infrastructure are the questions “ who regulates it ?” and “ to what extent ?” For example : Is your gas pipeline performing a transmission or bracewell . com