Pipeline Safety Regulation
- Managing a range of regulatory enforcement matters before PHMSA, including hazardous facility orders, jurisdictional determinations, and new construction, along with enforcement-related matters
- Offering an expansive approach to enforcement matters with varying levels of involvement based on client needs. Levels of involvement include advising clients in navigating interactions with PHMSA, engaging in informal consultation with PHMSA, assisting with drafting written responses to PHMSA enforcement allegations, and complete management of cases all the way to hearing and beyond.
- Advising owners and operators of gas and liquid pipelines, with varying complexity of systems and facilities, on the impact of proposed and new PHMSA regulations, PHMSA FAQs, and PHMSA guidance.
- Addressing non-enforcement-related interpretive and jurisdictional matters reaching the Congressional intent of the Pipeline Safety Act, as well as engaging in informal consultation with trade associations regarding Pipeline Safety Act reauthorizations.
- Negotiated the purchase of Oklahoma gas gathering systems and processing facilities by an independent pipeline company.
- Handled the structuring, financing, acquisition, and construction of Texas gas gathering systems.
- Experienced in vintage system evaluation and determination of return-to-service and conversion-to-service requirements, including regulatory, jurisdictional, and permitting/authorization.
- Secured acquisition financing of significant gas gathering, processing and transportation facilities in West Texas and Louisiana.
Longhorn Partners Pipeline, L.P.
Managed a wide range of tasks for the company, sunrise to sundown including:
- System Acquisition, including due diligence, negotiation and contracting
- Environmental Assessments, serving as lead counsel for all system, operational, integrity, regulatory, and mitigation matters addressed in a contentious, two-year National Environmental Policy Act review
- Mitigation construction to implementation of system-related mitigation measures and readying the system for startup
- Development of policies and procedures to implement O&M manual and mitigation measures
- Liaison with local, state and federal agencies and officials regarding all aspects of the pipeline system
- Expansion planning, including regulatory counseling, contracting, and agency liaison
- Ongoing operational contracting, including terminalling, transmix, MSAs, connections, ROW, land, and construction
- System sale and transition of sale to new owner, including agency liaison
In the area of Sensitive Security Information, Murchison Law Firm maintains current knowledge of the federal security apparatus, and we have advised clients in managing related information and processes. Chemical Facility Anti-Terrorism Standards also are within our expertise. Further, we have researched and advised clients on the FOIA exception for confidential business information (5 U.S.C. 552(b)) and Critical Infrastructure Information Act.