2025 Year in Review
In 2025, Bracewell’ s Oil & Gas Pipeline Regulatory practice continued to lead some of the most complex and consequential midstream, carbon management, and pipeline safety matters in the country. Our team— drawing on unmatched experience before FERC, PHMSA, the courts, and state agencies— guided clients through transformative infrastructure projects, rate and tariff proceedings and strategic planning, precedent-setting regulatory challenges, and shifting legislative, regulatory, and policy changes that shape the future of energy transportation.
A key highlight for our group in 2025 was Lauren Clegg joining us in our Washington, DC, office, 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.
Trailblazer Pipeline Conversion to CO₂ Transportation Service
Bracewell continued to advise Tallgrass Energy on the landmark conversion of approximately 450 miles of the Trailblazer Pipeline from natural gas service to gaseous CO₂ transportation— the first major US CO₂ transportation project built primarily through the repurposing of existing long haul natural gas infrastructure. Our work spans PHMSA compliance in an unsettled regulatory environment, including the absence of finalized federal CO₂ regulations following the Biden administration’ s withdrawn rulemaking. We also represented Tallgrass in securing FERC abandonment authority and supported commercial negotiations to establish Trailblazer as the backbone of a regional CO₂ transportation system linked to a Wyoming sequestration hub. Our role in advising Tallgrass on this conversion was highlighted by the Financial Times in honoring Bracewell as Most Innovative Law Firm in North America for Infrastructure at the FT Innovative Lawyer Awards North America 2025.
Counsel to Kinder Morgan on the Southern Natural Gas and Elba Express on South System Expansion IV
We advise Kinder Morgan’ s Southern Natural Gas and Elba Express affiliates on the $ 3.4 billion South System Expansion IV Project, a two-phase expansion adding 1.3 Bcf / d of capacity across 275 miles of new looping and compression. Bracewell leads the FERC certificate, siting, and environmental strategy efforts, while our pipeline safety lawyers oversee design, construction planning, and development of safety related filings in coordination with FERC and state agencies.
Successful Resolution of High-Profile Reverse FOIA Litigation Over Sensitive Pipeline Safety Data
Bracewell played a central role in successfully securing the protection of sensitive pipeline safety data from public disclosure under the Freedom of Information Act for
Sunoco Pipeline, L. P. This matter involved a high-profile, rare reverse FOIA action in the U. S. District Court for the District of Columbia that has spanned three presidential administrations, with the issue arising in May 2019, a lawsuit filed by Sunoco in June 2021, and resolution of the matter in 2025. The underlying decisions in the reverse FOIA action denying the government’ s motion to dismiss as well as PHMSA’ s determination that sensitive riskconsequence modeling information should be withheld from public disclosure will have precedential impacts across the pipeline industry and allow industry to better protect confidential and sensitive security information that is fundamental to their operations.
Tariff and Regulatory Matters for Phillips 66, Targa, Kinder Morgan and Others
Our team advised multiple oil & gas pipeline clients— including Phillips 66, Targa Resources, Kinder Morgan, and DT Midstream— on tariff restructuring, rate strategy, open seasons, and regulatory compliance. This included guiding industry responses to the D. C. Circuit’ s vacatur of the fiveyear oil pipeline rate index, which introduced significant uncertainty in oil pipeline rate structures and required rapid commercial and regulatory strategy adjustments.
Strategic Pipeline Safety Legislative, Rulemaking, and Policy Advocacy
Since the outset of the new presidential administration, Bracewell pipeline safety lawyers have been advising pipeline facility owners, operators, industry trade groups, and pipe manufacturers on PHMSA policy, deregulatory actions, and rulemaking initiatives which are likely to have a substantial impact on pipeline operations. This advocacy includes analysis and advice regarding( among other issues) reauthorization of the Pipeline Safety Act, implications associated with withdrawal of the leak detection and repair final rule and the proposed CO2 rule, overlap in statutory authority between PHMSA and FERC over LNG facilities, comments on pending rulemakings bracewell. com