REPRESENTATIVE EXPERIENCE Kirstin’s extensive representative experience includes:
FERC Regulatory Compliance and Enforcement
- Serving as lead counsel in a FERC enforcement matter involving a local distribution company.
- Serving as lead counsel to develop and implement FERC compliance programs and best practices, as well as training programs for natural gas trading and marketing clients, local distribution companies, natural gas pipelines, and end users.
- Serving as lead counsel responsible for internal audits and compliance investigations related to the FERC regulations applicable to natural gas trading and marketing companies, LNG and local distribution companies.
- Serving as the lead counsel conducting an internal investigation of two interstate pipelines’ compliance with FERC Standards of Conduct requirements.
- Providing ongoing advice on compliance with FERC regulatory requirements that impact natural gas pipelines and marketers, local distribution companies and LNG importers.
LNG
- Serving as lead regulatory counsel on behalf of an LNG importer with respect to ongoing negotiations of numerous capacity arrangements at the Cove Point Terminal and for all related implementation, rate and policy issues affecting capacity at the terminal as well as downstream natural gas transportation and storage.
- Serving as regulatory counsel on behalf of several LNG importers for the analysis of all federal regulatory issues affecting LNG importation and natural gas matters, including Natural Gas Act Section 3 and 7 authorization and certificate issues for LNG terminals and downstream pipelines, regasification and pipeline capacity transfer issues, and other rate and policy issues.
- Serving as regulatory counsel for securing U.S. Department of Energy import authorization for several LNG importers.
- Providing counsel to LNG importers in ongoing analysis of commercial, regulatory and policy developments affecting U.S. LNG terminals.
- Serving as counsel analyzing shippers’ rights and obligations under an LNG terminal tariff and numerous settlement agreements.
- Serving as lead regulatory counsel to an LNG importer and natural gas marketer in pipeline-specific natural gas interchangeability proceedings at FERC.
- Serving as lead regulatory counsel to an LNG importer and providing advice on general FERC policy matters involving capacity release and natural gas price transparency issues.
FERC and MMS Gas and Oil Pipeline Regulatory
- Counseling clients on jurisdictional and other questions related to siting oil and gas pipelines on the Outer Continental Shelf and onshore.
- Advising clients on compliance with the Interstate Commerce Act and the Outer Continental Shelf Lands Act requirements related to awarding capacity on new or expanded oil pipelines.
- Providing guidance to clients regarding the applicability of new Minerals Management Service (MMS) open access and non-discriminatory requirements for offshore oil pipelines.
- Reviewing precedent agreements on behalf of shipper clients for new and expanded oil pipeline facilities in the United States and Canada.
- Representing a shipper before FERC in a proceeding involving a diluent pipeline and providing commercial and transactional advice regarding the related Transportation Service Agreement and tariff provisions.
- Advising clients regarding FERC ratemaking issues involving capacity reserved for committed and uncommitted shippers.
PROFESSIONAL HONORS AND AWARDS
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of oil and gas regulation and litigation (2010)
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Member, Public Utility, Communications and Transportation Law Section, American Bar Association
- Member, Energy Bar Association
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- Speaker, "Best Practices for Creating a Compliance Program that Meets FERC Requirements," ACI's 3rd Annual Energy Trading Compliance Conference (September 22-23, 2009)
- Speaker, “Preparing for and Responding to Government Investigations and Audits,” ACI’s 3rd Annual Energy Trading Compliance Conference (September 22–23, 2009)
- Speaker, “On and Offshore LNG Regasification Terminals: Maximizing Potential,” LNG New Orleans (April 27–29, 2009)
- Chair and Speaker, Platts Gas Interchangeability and Quality Forum (November 19–20, 2008)
- Moderator, “Enforcement Across the Agencies,” Mid-Year Meeting, Energy Bar Association (November 13–14, 2008)
- Author, “LNG Importer Focus Turns to U.S. Interchangeability Rules,” LNG Journal (November/December 2007)
- Speaker, SMI LNG 2007 Conference (February 14–15, 2007)
- Speaker, Platts 2nd Annual Gas Interchangeability and Quality Forum (November 13–14, 2006)
- Author, “U.S. Gas Interchangeability Policy Ripples Through Global LNG Industry,” LNG Observer (October/December 2006)
- Speaker, Natural Gas Quality, Odorization, Energy Measurement, and Interchangeability Conference and Exhibition (July 11–12, 2006)
- Author, “Natural Gas Price Formation—Issues and Developments in 2003,” 2004 Natural Gas Regulation Committee Report (2004)
- Author, “Review of Order No. 637 Implementation Cases Energy Bar Association,” 2001 Natural Gas Regulation Committee Report (2001)