Susan A. Olenchuk

Partner

202.298.1896

sam@vnf.com

Assistant

1050 Thomas Jefferson Street NW
Seventh Floor
Washington, DC 20007


PHMSA Experience:

  • Provides regulatory compliance and strategic counseling on PHMSA’s regulatory policies including O&M, IM, DIMP, CRM, OQ, public awareness, reporting, and conversion to service, etc.
  • Counsels operators in PHMSA enforcement proceedings, federal court litigation, and appellate review.  Matters involve NOPVs, NOAs, safety orders, CAOs, petitions for reconsideration, petitions for review, jurisdictional challenges, and citizen suits.  Recent achievements include withdrawal of an NOPV; a settled outcome that eliminated a civil penalty in exchange for supplemental safety projects.
  • Counsels gas and hazardous liquid pipeline operators with respect to MAOP and MOP regulations and records review efforts.
  • Assists LDCs on state pipeline safety enforcement cases, incident investigations, and regulatory matters.
  • Assists interstate natural gas pipelines regarding rate, tariff, and certificate implications of pipeline safety policies and initiatives.
  • Advises operators on rulemakings,legislation and other policy initiatives and drafts comments. 
  • Advises pipeline operators on jurisdictional determinations.
  • Assists pipelines in private party, landowner, transactional, rate, and abandonment matters involving pipeline safety issues.
  • Assists pipeline operators on special permit issues.
  • Provides on-site seminars and training on PHMSA programs, policies, processes and jurisdiction.

 


FERC Experience:

  • Advises natural gas pipelines and customers in rate, tariff, certificate, and rulemaking proceedings.
  • Counsels natural gas pipelines and LDCs on implementation and compliance issues arising under FERC’s affiliate Standards of Conduct and undue preference policies.
  • Counsels pipelines on the jurisdictional issues associated with natural gas transportation and storage services provided under Section 311 of the NGPA.
  • Assists clients in auditing and evaluating internal processes and procedures and in developing workable and effective compliance plans and training materials that reflect best practices, conform with regulatory guidance and mandates, and achieve corporate objectives.
  • Represents clients before the federal courts of appeal in petition for review proceedings.

Publications

Pipeline Records Verification: Compliance Questions for Operators

Pipeline and Gas Journal, Vol. 239 Issue 9
09/01/2012

The Potential Impact of New Pipeline Safety Laws on PHMSA's Regulatory Initiatives

Pipeline and Gas Journal, Vol. 239 Issue 4
04/01/2012

Pipeline Safety: Attorneys Ready for the Challenge

Pipeline & Gas Journal, Vol. 238 Issue 8
08/01/2011

Hydro Licensing and the Endangered Species Act: Implications of FERC's Current Approach

Hydro Review
Recipient of the Author's Award as the No.1 ranked article by readers, Vol. 26 Issue 3
06/01/2007

Report of the Judicial Review Committee

Energy Law Journal, Vol. 27 Issue 1
06/01/2006

The Pipeline Safety Improvement Act of 2002

Energy Law Journal, co-authored with Theresa I. Zolet, Vol. 24 Issue 1
02/01/2003

Presentations

The Basics of FERC Ratemaking for Interstate Pipelines

Instructor, "FERC Ratemaking Under the Natural Gas Act"
New Mexico State University
Albuquerque, NM
10/10/2016

AGA 2016 Legal Forum

Presenter,"Pipeline Safety Act and the Impact of Proposed Regulations and New Legislation"
Asheville, NC
07/10/2016

Energy Bar Association Annual Conference

Panelist, "Known Knowns and Known Unknowns: Sifting Through Regulatory Changes in the Gas Pipeline Industry"
Energy Bar Association
Washington, DC
06/07/2016

2016 API Pipeline Conference

Moderator, "PHMSA Regulatory Agenda"
American Petroleum Institute
Carlsbad, CA
04/05/2016

The Basics of Natural Gas Pipeline Ratemaking Course

Instructor, FERC Ratemaking under the Natural Gas Act
New Mexico State University - Center for Public Utilities
Albuquerque, NM
10/11/2015

Shale Insight 2015

Panelist, "Pipeline Safety: Understanding Federal and State Regulatory Programs which affect Midstream Pipeline Operations"
Marcellus Shale Coalition
Philadelphia, PA
09/16/2015

6th Annual Pipe Tech Americas Summit

Speaker, "Preparing Your Pipelines for IVP"
San Antonio, TX
04/22/2015

The Basics of Natural Gas Pipeline Ratemaking Course

Instructor, FERC Ratemaking under the Natural Gas Act
New Mexico State University - Center for Public Utilities
Albuquerque, NM
10/12/2014

EBA's Natural Gas Primer: An Introduction to FERC Regulation of the Natural Gas Industry

Speaker, "What is Natural Gas?" "Historical Perspective and Industry Overview," and "Legal Overview: Key Statutes"
Energy Bar Association
Chicago, IL
05/19/2014