For more than four decades, Steptoe has been one of the nation's leading firms in the field of pipeline regulation. We have represented many of the largest crude oil and refined petroleum products pipeline systems in the United States and Canada, and have handled a number of groundbreaking proceedings in this highly technical area of law. We also have wide-ranging experience with natural gas pipelines and are regularly called upon to advise natural gas pipeline operators regarding regulation by the Federal Energy Regulatory Commission (FERC) and other agencies. Hailed by Chambers USA as "offering clients top-level regulatory advice on both oil and gas" issues, the firm has received the publication's "Award for Excellence" in the category of Energy: Oil & Gas, and is consistently ranked in "Band 1" for the category in both Chambers USA and Chambers Global.
Our team includes partners, counsel, and associates who focus their efforts on complex regulatory matters, as well as matters related to pipeline transactions, project development, pipeline safety and accident response (e.g., National Transportation Safety Board investigations), and FERC enforcement issues. We also counsel clients in the specialized area of Presidential Permits for cross-border pipelines and other pipeline permitting matters.
Noteworthy
- Chambers USA, Band 1, Energy: Oil & Gas, Nationwide (2008-2023)
- Chambers Global, Energy: Oil & Gas, US (2009-2021)
- Legal 500 US, Energy: Regulatory: Oil & Gas (2012-2022)
- Legal 500 US, Energy Litigation: Oil & Gas and Energy Regulation: Oil & Gas (2012, 2014, 2016, 2020-2021)
- Legal 500 US, Energy: Oil & Gas Regulatory and Litigation Nationwide (2022)
Steptoe is recognized as the industry leader in the field of oil pipeline regulation, and Chambers USA has cited the firm's "dominance in the oil pipeline area." For example, we have represented companies that share ownership of the Trans Alaska Pipeline System (TAPS) in almost every phase of the enormous volume of litigation surrounding the development and operation of the pipeline – starting with the environmental suits over routing and design, and broad challenges to rates for interstate movements. In recent years, we have also actively participated in the complex regulatory proceedings regarding interstate rates for transporting crude oil to in-state refiners in Alaska, as well as related proceedings concerning connections to the pipeline and capacity allocation.
In the lower 48 states, we provide pipeline counsel in connection with challenges to cost-of-service rates and applications for market-based rates. We also represent and provide counsel to a wide variety of crude oil, refined products, and natural gas liquids pipelines on questions of jurisdiction, terms of service, and standards of conduct.
Steptoe's wide-ranging experience with natural gas transactions and litigation includes:
- Representing pipeline companies in FERC rulemaking proceedings
- Advising interstate natural gas pipelines regarding FERC's Form 501-G requirements
- Advising on the federal approval process for natural gas pipeline projects
- Advising natural gas pipelines on a broad range of cost-of-service ratemaking issues, including income tax allowance and rate of return issues
- Assisting companies with FERC standards of conduct compliance
- Representing pipelines in connection with major pipeline incidents
We have handled a broad array of regulatory litigation before FERC and various state regulatory agencies, as well as appeals and other litigation in federal and state courts nationwide, including the US Supreme Court. In addition to standard litigation procedures, we also represent clients in alternative dispute resolution (ADR) proceedings and in negotiating and implementing complex regulatory settlements – including securing approval from federal and state regulators for such settlements and defending them in court.
Pipeline transactions present unique, complex challenges that frequently require a broad array of legal specialties. We provide counsel on mergers, acquisitions, and joint ventures; help negotiate contracts between pipelines and shippers; and create innovative rate structures and tariff approaches.
Our extensive regulatory experience translates into an ability to help clients structure complex transactions to good advantage, including:
- Sales and purchases of pipeline assets
- Joint ventures
- Pipeline leases
- Throughput agreements
- Joint tariff agreements
- Other arrangements specific to the pipeline industry
In addition to commercial and contractual issues, we also counsel domestic pipeline clients related to economic and access regulation by FERC and state agencies, antitrust review by the Federal Trade Commission (FTC), and tax issues specifically applicable to the various forms of pipeline entities. International pipeline transactions raise a host of additional issues, making the breadth of experience and depth of knowledge possessed by our attorneys an even greater asset.
In addition, we have substantial experience with operational issues affecting pipelines such as pipeline safety and right-of-way.
Our integrated lawyer team has direct experience in every important discipline and works together to efficiently guide our clients through the most complex and challenging pipeline transaction. This comprehensive approach allows our clients to spend less time managing multiple outside law firms, and more time focused on the business issues that drive the transaction.
Our pipeline lawyers are regularly called upon to advise companies with respect to questions of jurisdiction under the Interstate Commerce Act (ICA) and the Natural Gas Act (NGA), compliance with the non-discrimination and other provisions of the ICA and NGA, interpretation and application of FERC regulations, rate issues, tariff filing issues, pipeline safety issues, and a multitude of other questions related to the management and operation of oil and gas pipelines.
We also frequently counsel clients on pipeline regulatory issues in connection with various proposed transactions, including mergers and acquisitions of regulated pipelines, pipeline capacity leases, throughput and deficiency agreements, joint tariff agreements, and pipeline open seasons.
Steptoe's lawyers have extensive experience assisting clients with the strategic development of pipeline projects, including a full-range of land use, permitting, and environmental review issues. Our goal is to reduce the potential for project delay, and to ensure that agency decisions will be defensible if challenged. We advise clients with respect to permitting before a wide range of federal agencies, including the FERC, US Department of State, US Army Corps of Engineers, Bureau of Indian Affairs, US Forest Service, and the Bureau of Land Management. We advise interstate natural gas pipeline companies regarding the FERC certificate process. Our lawyers also represent pipeline companies throughout the environmental review process, including strategies to streamline NEPA and related reviews, including Endangered Species Act and National Historic Preservation Act consultations. Our experience also extends to assisting clients with consultations with Native American tribes, including obtaining rights-of-way across tribal lands.
Steptoe’s multidisciplinary pipeline accident team has extensive experience advising clients with respect to crude oil and hazardous liquid releases from pipelines as well as natural gas pipeline and utility explosions. Our team consists of regulatory, enforcement, litigation, and environmental lawyers who have in-depth knowledge of the entire pipeline incident process – from the first critical days of NTSB investigation, cleanup, and compliance with administrative orders issued by the US Environmental Protection Agency (EPA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA), to the negotiation and execution of a consent decree with the US Department of Justice (DOJ) to resolve natural resource damages as well as civil and criminal liability under the Clean Water Act (CWA). The ramifications from a pipeline accident can be dire and costly. Our lawyers’ goal is to manage that risk and minimize liability exposure for our pipeline clients. Our team has handled more than 35 NTSB investigations of which nine were pipeline accidents.
Our energy enforcement and investigations practice advises clients on potential violations of applicable law and defends clients that are the subject of FERC audits and enforcement actions. Our clients include all market participants, including traditional utilities, energy companies, pipelines, commodity traders, hedge funds and financial institutions, as well as their executives, traders, and compliance staff. We also assist clients with internal investigation and compliance audits, and provide extensive counseling related to maintaining compliant and up-to-date internal regulatory compliance programs.
We have extensive knowledge of the specific legal issues facing offshore pipelines, having served as lead counsel in FERC litigation regarding rates for a deepwater pipeline in the Gulf of Mexico and have been at the forefront of litigation regarding the extent of FERC jurisdiction over pipelines on the Outer Continental Shelf (OCS).
Beyond the US borders, the pipeline team is frequently called upon for representation and advice regarding projects and issues around the world. Since 2009, the practice has been consistently ranked highly in Chambers Global in the category of Energy: Oil & Gas (US).
Representative Matters
Steptoe represents pipelines before the Federal Energy Regulatory Commission (FERC), state regulatory agencies, and federal and state courts. The following is a list of representative recent matters:
FERC Rates
- Enbridge Energy, Limited Partnership, Docket No. IS21-352: Representing North America’s largest crude oil pipeline in its first general cost-of-service rate increase in thirty years.
- Colonial Pipeline Company, Docket No. OR18-7. Representing major refined products pipeline against a broad challenge to its rates across its system.
- Northern Natural Gas Company, Docket No. RP19-59. Defending the nation’s largest natural gas pipeline in section 5 investigation of its existing rates and a section 4 rate increase.
- Seaway Crude Pipeline Company, LLC, Docket No. OR15-6. Represented the pipeline in a multi-year proceeding that went to hearing at FERC, and successfully obtained approval of an application for market-based ratemaking authority for crude oil transportation from Cushing, Oklahoma to the US Gulf Coast.
- Trans Alaska Pipeline System, Docket No. IS11-306, et al. Defended ConocoPhillips Transportation Alaska, Inc. (one of the owners of the Trans Alaska Pipeline System) in a cost-of-service challenge to its 2009-2015 rates; we represented the carrier through all phases of the FERC and DC Circuit proceedings, ultimately obtaining a favorable settlement that resolved all pending rate matters and established a mechanism to calculate rates going forward.
- Seaway Crude Pipeline Company, LLC, Docket No. IS12-226. Defended the pipeline in a multi-year proceeding involving a cost-of-service challenge to its initial rate filing; after hearing and multiple FERC orders, we ultimately prevailed on all major issues, including preserving the pipeline’s committed shipper rates, obtaining approval for an approximately $1 billion purchase price adjustment to rate base, successfully defending the pipeline’s cost-of-capital proposals and income tax allowance, and obtaining approval for the pipeline’s proposed depreciation rates.
- Enbridge Energy, Limited Partnership, Docket No. IS17-170. Defended the pipeline against a challenge to the cost-of-debt component of its cost-of-service rates and helped obtain a favorable settlement of the matter.
- Colonial Pipeline Company, Docket No. OR14-18. Defended the pipeline against a challenge to its rates and helped obtain FERC approval for a settlement agreement resolving the proceeding.
- Enbridge Pipelines (North Dakota) LLC, Docket No. OR13-28. Obtained dismissal of a complaint challenging a rate surcharge used to fund an expansion.
- Enterprise TE Products Pipeline Company LLC, Docket No. IS12-203. Defended a refined products pipeline in a challenge to a cost-of-service rate filing and helped obtain FERC approval for a favorable settlement of the proceeding.
- Colonial Pipeline Company, Docket Nos. OR12-24. Defended the pipeline against a cost-of-service rate challenge brought by an individual industry watchdog; we obtained dismissal of the complaint by FERC on legal grounds and successfully defended FERC’s order at the DC Circuit.
- Mid-America Pipeline Company, LLC, Docket No. IS11-604. Defended the pipeline against a cost-of-service challenge to certain Central System interstate rates and helped obtain a favorable settlement of the matter.
- Mid-America Pipeline Company, LLC, Docket No. OR10-2. Defended the pipeline against a cost-of-service challenge to certain Northern System interstate rates and helped obtain a favorable settlement of the matter.
- Enbridge Pipeline (Southern Lights) LLC, Docket Nos. IS10-399 and IS11-146. Defended the pipeline against a cost-of-service challenge to its 2010-2011 rates; after hearing and a final FERC order, the Commission upheld the proposed rates in all respects.
- Kuparuk Transportation Company, Docket No. IS10-209. Defended the pipeline against a challenge to its 2008-2010 interstate rates and helped craft a long-term settlement agreement that resolved that proceeding and continues to govern the pipeline’s rates.
- Mid-America Pipeline Company and Seminole Pipeline Company, Docket Nos. IS05-216, et al. Defended the pipelines in a cost-of-service challenge to their company-wide 2005-2006 rates; after hearing and an ALJ decision, we obtained a FERC-approved settlement that largely resolved the issues in the case on mutually-agreeable terms; we helped obtain a generally favorable FERC decision on the remaining issues.
- Frontier Pipeline Company, Docket Nos. OR01-2, et al. Obtained a favorable DC Circuit decision on behalf of the pipeline regarding the standard for evaluating joint tariff rates and the availability of reparations for non-shippers.
- Alpine Transportation Company, Docket No. IS01-33. Defended the pipeline against a cost-of-service challenge to its initial rate filing and helped obtain FERC approval for a long-term settlement agreement that resolved that proceeding and continues to govern the pipeline’s rates.
- ExxonMobil Pipeline Company, Docket No. 00-221. Defended the pipeline against a cost-of-service challenge to its initial rate filing and helped negotiate a favorable settlement of the matter.
- Trans Alaska Pipeline System, Docket No. IS05-82, et al. Defended ConocoPhillips Transportation Alaska, Inc. (one of the owners of the Trans Alaska Pipeline System) in a cost-of-service challenge to its 2005-2006 rates; we represented the carrier through all phases of the FERC and DC Circuit proceedings ultimately obtaining new just and reasonable rates for the company while minimizing the carrier’s refund exposure.
- Trans Alaska Pipeline System, Docket No. IS08-78, et al. Defended ConocoPhillips Transportation Alaska, Inc. in a cost-of-service challenge to the 2008 TAPS rates and helped obtain FERC approval for a favorable settlement of the matter.
- Mid-America Pipeline Company, Docket No. IS08-182. Defended the pipeline against a 2008 cost-of-service rate challenge and helped settle the matter on mutually-agreeable terms prior to hearing.
FERC Jurisdiction and Pipeline Practices
- Sunoco Pipeline, L.P., Docket No. OR15-25. Defended the pipeline against a complaint filed by a shipper challenging throughput and deficiency agreements the pipeline had entered into with other shippers. We guided the pipeline through an innovative settlement reached prior to issuance of a Commission decision.
- Enterprise TE Products Pipeline Company LLC, Docket Nos. OR13-25 and OR13-26. Defended the pipeline against complaints regarding cancellation of jet fuel and distillate movements; obtained a FERC ruling that it lacks authority to prohibit pipeline abandonment of transportation service for individual products and successfully defended FERC's decision at the DC Circuit; helped settled certain related contract damages claims.
- Colonial Pipeline Company, Docket No. IS17-522. Obtained dismissal of a challenge to certain biodiesel blending activities on the ground that the blending activities were not subject to the Commission's jurisdiction.
- Mid-America Pipeline Company, LLC, Docket No. IS14-587, and Chaparral Pipeline Company, LLC, Docket Nos. IS14-591. Successfully obtained dismissal of challenges to pipeline proposals to increase the monetary penalties for shippers that failed to deliver product consistent with the pipeline's specifications.
- Enbridge Energy, Limited Partnership, Docket Nos. IS13-17 and OR13-15. Successfully defended Enbridge's nomination verification procedures against various challenges and obtained Commission approval after a technical conference.
- Colonial Pipeline Company, Docket No. IS13-11. Obtained dismissal of a protest of the pipeline's proposed specifications regarding Ultra Low Sulfur Diesel movements.
- Dixie Pipeline Company LLC, Docket No. IS12-214. Obtained FERC approval for a pipeline proposal to batch butane and isobutane on a pipeline previously dedicated largely to propane movements.
- Enbridge Energy, Limited Partnership, Docket No. OR12-17. Obtained dismissal of a complaint seeking to force a pipeline to connect.
- Enbridge Energy, Limited Partnership, Docket No. OR12-14. Successfully defended against challenge to pipeline proration policies.
- Enterprise TE Products Pipeline Company LLC, Docket No. OR11-3. Obtained dismissal of a complaint that sought to require the pipeline to enter into an exchange or "backhaul" movement.
- Enterprise TE Products Pipeline Company LLC, Docket No. IS10-203. Defended the pipeline against a challenge to its propane inventory policy and helped obtain FERC approval of a favorable settlement of the matter.
- Mid-America Pipeline Company, LLC, Docket No. IS10-168. Helped obtain a FERC ruling that the Commission has no jurisdiction over the cancellation of service for certain individual products moved by a batched natural gas liquids pipeline.
- TE Products Pipeline Company, LLC, Docket No. IS10-160. Successfully defended the pipeline against a challenge to its cancellation of certain terminalling services, obtaining a FERC ruling that the terminalling services are not FERC jurisdictional.
- Enbridge Energy, Limited Partnership, Docket Nos. IS10-137, IS10-138, IS10-139, OR10-5. Defeated a shipper attempt to keep Enbridge’s Alberta Clipper project from going into service.
- Trans Alaska Pipeline System, Docket No. IS09-348, et al. Represented ConocoPhillips Transportation Alaska, Inc. in a dispute among the TAPS owners regarding the sharing of system costs and helped obtain a favorable settlement agreement, which included a "pooling agreement" approved by FERC and upheld by the DC Circuit.
- Dixie Pipeline Company, Docket No. IS08-449. Obtained FERC approval for a proposal to provide emergency transportation of various natural gas liquids on a pipeline historically dedicated primarily to propane movements in order to accommodate industry needs as a result of hurricane damage in the Gulf Coast area.
- Western Refining Pipeline Company, Docket No. IS08-131. Successfully defended the pipeline against a complaint seeking to require it to provide an exchange or backhaul for transportation in the opposite direction of pipeline’s flow; we obtained a FERC order dismissing the complaint and successfully defended FERC’s order at the DC Circuit.
- ConocoPhillips Transportation Alaska, Inc., Docket No. IS05-449. Defended the pipeline in a protest to its proration policy, obtaining dismissal of the protest.
- Enterprise Lou-Tex Propylene Pipeline L.P., Docket No. IS05-117. Obtained a favorable FERC decision that it lacks jurisdiction over pipeline transportation of chemical grade propylene.
- Sabine Propylene Pipeline L.P., Docket No. IS04-487. Obtained a favorable FERC decision that it lacks jurisdiction over pipeline transportation of polymer grade propylene.
- Amberjack Pipeline Company, Docket No. IS02-42. Obtained a favorable FERC decision that it lacks jurisdiction over pipeline transportation occurring wholly on the Outer Continental Shelf.
Industry Advocacy
- Association of Oil Pipe Lines, Docket No. RM15-20. Represented the oil pipeline trade association ("AOPL") in connection with FERC's five-year review of the inflation-based index for oil pipelines for the period from 2016-2021, both before the agency and the DC Circuit.
- Association of Oil Pipe Lines, Docket No. RM10-25. Represented AOPL in connection with FERC’s five-year review of the inflation-based index for oil pipelines for the period from 2011-2016.
- Association of Oil Pipe Lines, Docket No. PL07-2. Represented AOPL in connection with FERC’s review of its policies regarding calculation of the rate of return on equity and income tax allowance for master limited partnership pipelines and helped obtain a generally favorable result.
- Upstate Forever and Savannah Riverkeeper v. Kinder Morgan Energy Partners L.P. and Plantation Pipe Line Company, Inc., No. 17-1640 (4th Cir. Sept. 8, 2017). Represented trade groups as amici in lawsuit involving a challenge to pipeline company’s compliance with the Clean Water Act for existing pipeline; amici briefs filed at district court and appellate levels.
- Standing Rock Sioux Tribe, et al., v. US Army Corps of Engineers, et al., 1:16-cv-01534 (JEB) ECF No. 259-1 (D.D.C., filed July 17, 2017). Represented trade groups as amici in lawsuit involving tribal groups’ challenge to the US Corp of Engineers’ compliance with NEPA, the NHPA, and other laws for approval required for Dakota Access pipeline.
- National Wildlife Federation v. Secretary of the US Department of Transportation, 2:15-cv-13535 (MAG-RSW) ECF No. 53 (E.D. Mich., filed July 6, 2017). Represented the American Petroleum Institute and the Association of Oil Pipe Lines as amici in lawsuit involving a challenge to agency's compliance with the Clean Water Act in approving emergency response plans for liquids pipelines.
- Portland Pipe Line Corporation v. City of South Portland, Maine, Civil Action No. 2:15-cv-00054-JAW (D. Me., Jan. 11, 2017). Represented trade associations as amici in lawsuit involving challenge to city’s ordinance banning the off-loading of crude oil onto barges in the South Portland harbor.
Pipeline Permitting
- Sierra Club v. US Forest Service, 828 F.3d 402 (6th Cir. 2016). Successfully represented pipeline company as an intervenor in challenge to US Forest Service's compliance with NEPA and the ESA in renewing permit to allow pipeline to continue to cross forest lands).
- Sierra Club v. US Army Corps of Engineers, et al., 803 F.3d 31 (DC Cir. 2015). Earned favorable ruling for intervenor pipeline company in a NEPA and CWA-based challenge to multiple federal agency permits for a domestic oil pipeline;
- NWF v. Department of Transportation, et al., 2:17-cv-10031 (MAG) (E.D. Mich., complaint filed Jan. 5, 2017). Represent intervenor pipeline company in challenge to emergency response plans for company's underwater pipeline.
- White Earth, et al. v. US Department of State, et al., 14-cv-4726, 2015 WL 8483278 (D. Minn. Dec. 9, 2015). Obtained summary judgment decision in favor of intervenor pipeline company in challenges to the US Department of State’s compliance with NEPA concerning cross-border pipelines.
- Sierra Club v. Clinton, 689 F. Supp. 2d 1147 (D. Minn. 2010). Assisted intervenor pipeline company in NEPA challenge to Presidential Permit for cross-border pipeline.
Matters Before State Regulatory Agencies
- Trans Alaska Pipeline System, Docket No. P-08-9. Defended the pipeline against challenges to its 2008-2014 intrastate rates before the Regulatory Commission of Alaska, ultimately obtaining a favorable settlement that resolved all pending rate matters through mid-2019.
- Trans Alaska Pipeline System, Docket No. P-03-4. Defended the pipeline against challenges to its 2001-2002 intrastate rates before the Regulatory Commission of Alaska.
- Trans Alaska Pipeline System, Docket No. P-97-4. Defended the pipeline against challenges to its 1996-2000 intrastate rates before the Regulatory Commission of Alaska.
- Alpine Transportation Company, Docket No. P-00-15. Defended the pipeline against a cost-of-service challenge to its initial rate filing and helped obtain Regulatory Commission of Alaska approval for a long-term settlement agreement that resolved that proceeding and continues to govern the pipeline’s intrastate rates.
- Kuparuk Transportation Company, Docket Nos. P-08-5, P-08-11 and P-10-6. Defended the pipeline against a challenge to its 2008-2010 intrastate rates and helped craft a long-term settlement agreement that resolved the matter as well as establishing pipeline’s intrastate rates going forward.
- Cook Inlet Pipe Line Company, Docket No. P-04-11. Defended the pipeline against a challenge to its gravity bank methodology and helped obtain a favorable settlement of the matter.
Open Seasons and Petitions for Declaratory Orders
Steptoe represents pipeline carriers in all aspects of FERC open seasons, including drafting and negotiating transportation services agreements and dedication agreements, developing or adapting tariffs to provide for committed volumes and other applicable open season terms, drafting the terms and conditions for the open season and drafting petitions for declaratory order. The following is a list of representative projects where we obtained declaratory orders from the FERC (pending matters and transactions for which we did not seek declaratory orders are not included). In most of these projects, we represented the client in all aspects of the open season.
- Western Refining Conan Gathering LLC, Docket No. OR17-15. Obtained FERC approval of a petition for declaratory order regarding Western’s Conan Project involving a crude oil pipeline in New Mexico and Texas.
- Wolverine Pipe Line Company, Docket No. OR 15-33. Obtained FERC approval of a petition for declaratory order regarding existing and expansion capacity of a refined petroleum products pipeline.
- Phillips 66 Carrier LLC, Docket No. OR15-29. Obtained FERC approval of a petition for declaratory order regarding a proposed expansion of a refined petroleum products pipeline.
- Kinder Morgan Cochin LLC, Docket No. OR15-28. Obtained FERC approval of a petition for declaratory order for Kinder Morgan’s Utopia East project involving natural gas liquids transportation from the Utica shale region.
- Sunoco Pipeline L.P., Docket No. OR15-18. Obtained FERC approval of a petition for declaratory order for Sunoco’s Delaware Basin Extension Project involving a proposed crude oil pipeline in New Mexico and Texas.
- Panola Pipeline Company LLC, Docket No. OR15-14. Obtained FERC approval of a petition for declaratory order for an expansion of Enterprise’s Panola Pipeline in Texas.
- Sunoco Pipeline L.P., Docket No. OR14-40. Obtained FERC approval of a petition for declaratory order for Sunoco’s proposed Mariner East 2 project that would transport propane, butane and ethane from origin points in West Virginia, Ohio and Pennsylvania to a terminal in Pennsylvania and Delaware.
- North Dakota Pipeline Company LLC, Docket No. OR14-21. Obtained FERC approval of a petition for declaratory order for the Sandpiper Pipeline which would transport crude oil from the Bakken in North Dakota to Clearbrook, Minnesota and Superior, Wisconsin.
- Sunoco Pipeline L.P., Docket No. OR14-7. Obtained FERC approval of a petition for declaratory order for Sunoco’s Granite Wash Extension Pipeline involving a proposed crude oil pipeline in Texas.
- Enbridge Pipelines (FSP) LLC, Docket OR14-5. Obtained FERC approval of a petition for declaratory order for Enbridge’s Flanagan South Pipeline Project from Flanagan, Illinois to the Gulf Coast.
- Sunoco Pipeline L.P., Docket No. OR14-2. Obtained FERC approval of a petition for declaratory order for Sunoco’s Eaglebine Express Project involving a proposed crude oil pipeline in Texas.
- Sunoco Pipeline L.P., Docket No. OR13-30. Obtained FERC approval of a petition for declaratory order for Sunoco’s Mariner South project involving transportation of natural gas liquids and petroleum products in Texas.
- Enterprise Liquids Pipeline LLC, Docket No. OR13-24. Obtained FERC approval of a petition for declaratory order regarding the Aegis Pipeline project to transport purity ethane to the Gulf Coast.
- Enterprise TE Products Pipeline Company LLC, Docket No. OR13-20. We obtained FERC approval of a petition for declaratory order regarding a proposed expansion to provide new diluent transportation capacity.
- Enbridge Pipelines (Illinois) LLC, Docket No. OR13-19. We obtained FERC approval of a petition for declaratory order for Enbridge’s Southern Access Extension project, which provided new pipeline capacity to transport crude oil from Flanagan to Patoka, Illinois.
- Sunoco Pipeline L.P., Docket No. OR13-9. Obtained FERC approval of a petition for declaratory order for Sunoco’s Mariner East project involving transportation of ethane and propane from Pennsylvania to a terminal located in Pennsylvania and Delaware.
- Enterprise Liquids Pipeline LLC, Docket No. OR13-7. Obtained FERC approval of a petition for declaratory order regarding the ATEX Pipeline project to provide ethane transportation from the Marcellus/Utica region to the Gulf Coast.
- Sunoco Pipeline L.P., Docket No. OR13-2. Obtained FERC approval of a petition for declaratory order for Sunoco’s Permian Express project involving crude oil transportation from West Texas, New Mexico and Oklahoma to the Nederland/Beaumont, Texas markets.
- Enbridge Pipelines (Southern Lights) LLC, Docket No. OR12-27. Obtained FERC approval of a contractual right of first offer in an earlier transportation services agreement in preparation for an additional open season for Enbridge’s condensate pipeline from Chicago, Illinois to the Canadian border.
- Sunoco Pipeline L.P., West Texas Gulf Pipe Line Company and Mobil Pipe Line Company, Docket No. OR12-16. Obtained FERC approval of a petition for declaratory order for petitioners’ West Texas-Nederland project.
- Sunoco Pipeline L.P., Docket No. OR12-12. Obtained FERC approval of a petition for declaratory order for Sunoco’s Longview Access and Houston Access projects.
- Sunoco Pipeline L.P., Docket No. OR11-22. Obtained FERC approval of a petition for declaratory order for Sunoco’s Mariner West project involving transportation of natural gas liquids and refined petroleum products from Ohio to Michigan, Pennsylvania and Ontario, Canada.
- Mid-America Pipeline Company, LLC, Docket No. OR11-11. Obtained FERC approval of a petition for declaratory order regarding a proposed expansion of the Mid-America’s Rocky Mountain pipeline system.
- Skelly-Belvieu Pipeline Company, L.L.C., Docket No. OR12-6. Obtained FERC approval of a petition for declaratory order regarding a proposed expansion of a natural gas liquids pipeline.
- Enbridge Pipelines (North Dakota) LLC and Enbridge Pipelines (Bakken) L.P., Docket No. OR10-19. Obtained FERC approval of a petition for declaratory order with respect to the expansion of Enbridge’s North Dakota Pipeline and Bakken Pipelines.
- Enbridge (U.S.) Inc. and ExxonMobil Pipeline Company, Docket No. OR08-7. Obtained FERC approval of a petition for declaratory order including a request for approval of the proposed prorationing policy for a proposed new crude pipeline from Patoka, Illinois to the Gulf Coast.
- CCPS Transportation LLC, Docket No. OR07-17. Obtained FERC approval of a petition for declaratory order including a request for approval of firm service to shippers committing to ship on an expansion of Enbridge’s Spearhead pipeline
- Enbridge Pipelines (Southern Lights) LLC, Docket No. OR07-15. Obtained FERC approval of certain agreed committed rate principles for a new condensate pipeline from Chicago, Illinois to the Canadian border.
- Enbridge Energy Company, Inc., Docket No. OR05-1. Obtained FERC approval of a petition for declaratory order regarding the proposed rate structure for Enbridge’s Spearhead Pipeline project, which involved reversing an existing oil pipeline to run from Chicago to Cushing.
News & Publications
Media Mentions
February 16, 2024
Client Alerts
November 27, 2023
Press Releases
Steptoe Receives 28 Practice Rankings, 34 Individual Awards in Legal 500 US 2023
June 14, 2023
Press Releases
Steptoe Receives 16 Practice, 40 Individual Mentions in Chambers Global 2023
February 21, 2023
Press Releases
January 19, 2023
Client Alerts
Third Circuit Bars Claims Against Colonial Based on Filed Rate Doctrine
October 7, 2022
By: Jennifer Quinn-Barabanov, Shaun Boedicker, Mark C. Savignac
Press Releases
Steptoe Receives 27 Practice Rankings, 26 Individual Awards in Legal 500 US 2022
June 16, 2022
Events
Webinars
How Will the 2017 Tax Act Affect FERC-Regulated Oil Pipeline Rates?
January 23, 2018
Speakers: Aaron P. Nocjar, Daniel J. Poynor, Steven Reed
Webinars
Pipeline Accidents: Are You Prepared?
September 26, 2017
Speakers: David H. Coburn, William T. Hassler, Joshua Runyan, Steven Reed
Webinars
Pipeline Accidents: Are You Prepared?
April 5, 2017
Speakers: Jennifer Quinn-Barabanov, Robert L. Shuftan, Steven Reed
Webinars
Real World Accident Response: The NTSB
February 28, 2017
Speakers: David H. Coburn, Dane Jaques
Webinars
Pipeline Accidents: Are You Prepared?
January 12, 2017
Speakers: Seth Goldberg, William T. Hassler, Dane Jaques, Joshua Runyan
Webinars
Pipeline Accidents: Are You Prepared?
December 1, 2016
Speakers: Dane Jaques, Joshua Runyan, Steven Reed