Susan Olenchuk has nearly three decades of experience providing strategic counsel on pipeline safety compliance, enforcement, and policy matters before the Pipeline and Hazardous Materials Safety Administration (PHMSA) and state pipeline agencies, as well as on rate, tariff, certificate, compliance and enforcement matters before the Federal Energy Regulatory Commission (FERC). A former President of the Energy Bar Association, 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
Known for her deep knowledge of pipeline safety issues, Susan represents operators of gas transmission and distribution pipelines, natural gas underground storage facilities, hazardous liquid pipelines, and LNG facilities in enforcement matters before the PHMSA and state agencies. She works with in-house counsel, engineers, and consultants to prepare thoughtful, well-supported factual and legal arguments to ensure due process and achieve satisfactory outcomes. When necessary, she defends clients in administrative litigation and represents them in federal courts.
Susan also works with clients to address day-to-day compliance questions involving the pipeline safety regulations of both the PHMSA and state regulators and counsels on emerging regulatory issues, such as the jurisdictional status and regulation of pipelines carrying renewable natural gas (RNG), the safety of pipelines transporting hydrogen gas blends, and anticipated new regulations of pipelines that transport CO2. She also helps clients engage in rulemaking proceedings, counsels on legislative matters, and provides on-site seminars and training on PHMSA programs, policies, processes, and jurisdiction for CLE credit.
FERC Compliance Counseling
Susan has significant experience counseling 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. Clients benefit from her experience evaluating internal processes and procedures and developing workable and effective compliance plans and training materials that reflect best practices, conform with regulatory guidance and mandates, and achieve corporate objectives.