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Suzanne E. Clevenger
Suzanne E. Clevenger
Partner — Energy Regulation
Partner — Energy Regulation

Suzanne E. Clevenger

Suzanne E. Clevenger
Houston

1001 Fannin Street
Suite 2500
Houston, TX 77002

Suzanne E. Clevenger

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, and agreements for the purchase and sale of commodities.

Experience Highlights

  • 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

Credentials

  • University of Houston Law Center, J.D. summa cum laude,  2008 (Order of the Coif; Order of the Barons; Houston Law Review)
  • Texas A&M University, B.S., Mechanical Engineering magna cum laude, 2002
  • 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.
  • Legal 500 U.S., Energy Regulation: Oil & Gas, 2019
  • Member: Energy Bar Association, Houston Bar Association
  • Texas
  • “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)