Suzanne counsels clients with respect to regulated and unregulated midstream assets. Specifically, Suzanne focuses on FERC regulatory requirements and compliance with FERC regulations, including creation of regulatory compliance and internal audit programs, rate regulation of natural gas pipelines and storage companies, and regulatory requirements at FERC for developing liquids and natural gas pipelines. Suzanne also works with clients on the negotiations of midstream agreements, including for service on interstate gas and liquids pipelines, gathering pipelines, processing facilities, storage terminal agreements, agreements for the purchase and sale of commodities, gas rights agreements and related facilities agreements for renewable natural gas.
Experience
Participates in the preparation, filing, and prosecution of certificate applications and requests for abandonment authorization at FERC involving major interstate natural gas companies located in the United States, including expansion projects, and new greenfield pipeline and storage facility projects
Represented a major natural gas pipeline company in a rate case proceeding and defended settlement over opposition before the FERC
Represented a major natural gas pipeline company in a rate case proceeding before the FERC
Represented a major interstate natural gas pipeline located in the United States in connection with obtaining regulatory approvals from FERC for negotiated rate agreements with customers and tariff revisions
Created and implemented regulatory compliance initiatives for major United States natural gas pipelines, along with the drafting and implementation of internal compliance manuals for major United States natural gas pipelines
Advised clients regarding jurisdictional analysis of pipelines, including gathering determinations, Section 311 regulations, and Hinshaw regulations
Advised a developer of interstate refined products pipelines on the Gulf Coast regarding FERC rate and tariff requirements for new pipelines, including associated policies regarding shipper commitments, open seasons, and the filing of a petition for declaratory order
Represented a major E&P company in the negotiation of a portfolio of midstream agreements related to a joint venture with another major midstream company related to the construction and use of midstream facilities
Represented a major E&P company in negotiating revisions to midstream agreements in order to make the underlying production assets attractive for potential buyers
Represented clients in the negotiation of midstream agreements and amendments to existing midstream agreements
Advised numerous clients in sales and acquisitions of oil and gas assets, including pipeline and production assets, regarding regulatory issues, including obtaining FERC approvals for the assignment of transportation agreements
Before becoming an attorney, Suzanne was employed at a major natural gas pipeline and storage company for six years (2002–2008), including four years in the engineering department and two years in the internal regulatory department. Her work in the engineering department included cost management initiatives for major natural gas pipeline expansion projects. Her experience in the internal regulatory department primarily focused on natural gas pipeline and storage certificate applications at FERC involving expansion projects and new storage projects located in the Northeast and Southeast United States. Additionally, Suzanne assisted with the preparation, filing, and prosecution of requests for market-based rate authorizations from the FERC for interstate natural gas storage companies, and assisted with filing regulatory compliance documents and creating regulatory compliance manuals.
Member: Energy Bar Association, Houston Bar Association
“FERC Tax Orders Webcast & Teleconference,” March 23, 2018 (speaker)
“FERC Order on Marketing Affiliates Under the ICA,” V&E Energy Regulation Insights E-communication, December 11, 2017 (co-author)
“Upstream Transactional Update: DrillCos Under Review and Producer Midstream Gathering JVs,” V&E Houston Office, November 8, 2017 (speaker)
Recognitions
Chambers Global, Energy: Oil & Gas (Regulatory & Litigation) (USA), 2022–2026; “Up and Coming” in Energy: Oil & Gas (Regulatory & Litigation)(USA), 2022 and 2023
Chambers USA, Energy: Oil & Gas (Regulatory & Litigation)(Nationwide), 2021–2026; “Up and Coming” in Energy: Oil & Gas (Regulatory & Litigation) (Nationwide), 2021 and 2022
Legal 500 U.S., Energy Regulation: Oil & Gas, 2019–2026; Energy Regulation: Electric Power, 2024–2026
In a significant order addressing the rate design and regulatory compliance obligations of intrastate pipelines providing interstate transportation service under Section 311 of the Natural Gas Policy Act of 1978 (“NGPA”), the Federal Energy Regulatory Commission (“FERC” or the “Commission”) has clarified the application of the Straight-Fixed Variable (“SFV”) rate design methodology and minimum rate requirements applicable to pipelines offering service under NGPA Section 311.
Vinson & Elkins is pleased to offer this round-up of recent developments in federal enforcement, with a particular emphasis on changes during the first few months of the second Trump administration.
On July 3, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”), the U.S. Army Corps of Engineers (“Army Corps”), and the Departments of Energy (“DOE”), Interior (“DOI”), Transportation (“DOT”), Agriculture (“USDA”), and Defense (“DOD”) released sweeping updates to their regulations and procedures implementing the National Environmental Policy Act (“NEPA”).
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