Susan Olenchuk counsels clients in the oil and gas industry on pipeline safety matters before PHMSA’s Office of Pipeline Safety, and on rate, tariff, certificate, compliance and enforcement matters before FERC. She also represents clients in federal appellate proceedings. She melds her knowledge and experience in these areas to collaborate with clients to resolve challenges in achieving their safety, legal and business objectives.
Pipeline Safety Regulatory and Strategic Counseling
Susan provides regulatory, policy, and strategic counseling to operators of gas and hazardous liquid pipelines and LNG facilities on day-to-day applications of complex regulatory requirements. For example, clients seek Susan’s counsel when they need assistance understanding how particular regulations apply to unanticipated or complex circumstances, understanding the scope and application of new regulations, determining whether facilities are subject to PHMSA’s regulation, and managing potential non-compliance situations. Susan also counsels clients in rulemaking proceedings and on other policy initiatives, helping clients prepare written comments and advising on legislative initiatives.
Susan defends operators in enforcement proceedings before PHMSA and state regulatory agencies. A recent success involved the withdrawal of an NOPV that had been filed against a gas pipeline client. She also helped negotiate the settlement of an enforcement proceeding, including the withdrawal of a proposed civil penalty in exchange for supplemental safety projects. Susan also represents clients before federal courts and provides guidance following incidents.
FERC Compliance Counseling
Susan counsels on rate, tariff, certificate, compliance and rulemaking proceedings affecting natural gas pipelines. In particular, pipeline safety policies and initiatives can affect a pipeline’s approach to a rate, tariff, or abandonment issue. Susan also advises on corporate compliance matters under FERC’s affiliate Standards of Conduct and undue preference requirements under the Natural Gas Act. For example, FERC’s policy regarding communications between pipelines and electric transmission providers may affect how a company uses shared employees across multiple business units or affiliates. Susan also counsels on jurisdictional and other issues under Section 311 of the Natural Gas Policy Act. Susan assists clients in evaluating internal processes and procedures and in developing workable and effective compliance plans and training materials that reflect best practices, conform with regulatory guidance and mandates, and achieve corporate objectives. Susan also represents clients before the federal courts of appeal in petition for review proceedings.
The Catholic University of America, Columbus School of Law
J.D., cum laude, 1997
University of Michigan
"Best Lawyers in America" by Best Lawyers
Energy Law, 2014-2018
Energy Bar Association
Vice President, 2010-2011
Assistant Treasurer, 2007-2009
Foundation of the Energy Law Journal
Board of Directors, 2010-2013
Charitable Foundation of the Energy Bar Association
Board of Directors, 2007, 2010-2013
FERC Rate Course for the Natural Gas Interstate Pipeline Industry, sponsored by the Center for Public Utilities at the New Mexico State University
Instructor and Advisor, 2010 - Present