Susan Olenchuk counsels clients on pipeline safety compliance, enforcement, and policy matters before the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Office of Pipeline Safety, and on rate, tariff, certificate, compliance and enforcement matters before the Federal Energy Regulatory Commission (FERC). She also represents clients in federal courts of appeal. Susan is a member of Van Ness Feldman’s Executive Committee and previously served as a practice group leader of the Firm’s Pipeline & LNG Practice.
Pipeline Safety Compliance, Enforcement and Strategic Counseling
Susan helps operators of gas transmission and distribution pipelines, hazardous liquid pipelines and LNG facilities navigate day-to-day compliance questions on an array of issues that arise under PHMSA’s pipeline safety regulations. She helps clients think through how the regulations and other guidance apply in both routine and unanticipated operational situations and affect company decision-making. She also helps clients think through emerging regulatory issues, such as the safety regulation of pipelines carrying renewable natural gas and hydrogen. Susan also assists clients in enforcement matters before both PHMSA and state agencies, working with in-house counsel, engineers, and consultants to prepare thoughtful, well-supported factual and legal arguments to help achieve satisfactory outcomes while ensuring the preservation of due process. Susan also counsels on rulemaking proceedings and legislative matters and she provides on-site seminars and training on PHMSA programs, policies, processes and jurisdiction.
FERC Compliance Counseling
Susan counsels on rate, tariff, certificate, compliance and rulemaking proceedings affecting natural gas pipelines. She advises on corporate compliance matters under FERC’s affiliate Standards of Conduct and undue preference requirements under the Natural Gas Act. She also 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.