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 in 2025 was Lauren Clegg in our Washington DC office. Lauren joined Bracewell after a decade at the Pipeline and Hazardous Materials Safety Administration( PHMSA) within the U. S. Department of Transportation, where she was most recently the deputy assistant chief counsel for the Office of Chief Counsel in PHMSA’ s Pipeline Safety Division.
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