Paul Forshay

Paul Forshay

Sutherland Asbill & Brennan LLP

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Latest Publications


Update: FERC Five-Year Review of Oil Pipeline Rate Indexation

On June 30, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) that proposed an adjustment to the annual indexation formula for oil pipeline rates. The NOI sought comments on a proposed...more

8/5/2015 - Comment Period FERC Notice of Inquiry Oil & Gas Pipelines Technical Conference

D.C. Circuit Vacates 100-Hour Exemption for Emergency Generators

On May 1, 2015, the D.C. Circuit in Delaware v. EPA vacated a portion of EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for Reciprocating Internal...more

5/6/2015 - Emergency Generators EPA Pollution Control Power Grid

FERC Issues Policy Statement On Natural Gas Pipeline Modernization Cost Recovery

On April 16, 2015, FERC issued a Policy Statement in Cost Recovery Mechanisms for Modernization of Natural Gas Facilities, Docket No. PL15-1-000, 151 FERC ¶ 61,047 (2015). Effective October 1, 2015, the Policy Statement...more

4/23/2015 - Cost Recovery Energy Sector EPA FERC Natural Gas Oil & Gas PHMSA Pipelines Policy Statement

FERC Issues Order No. 809 On Gas/Electric Coordination

On April 16, 2015, FERC issued a Final Rule in Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, Order No. 809, Docket No. RM14-2-000, 151 FERC ¶ 61,049 (2015). Recent cold...more

4/23/2015 - Electric Generation Suppliers Electricity Energy Sector FERC Final Rules NAESB Natural Gas Oil & Gas Pipelines Tariffs

FERC Issues Proposed Policy Statement on Cost Recovery Mechanisms for Modernization of Natural Gas Facilities

On November 20, the Federal Energy Regulatory Commission (Commission) issued a Proposed Policy Statement on cost recovery mechanisms, such as trackers or surcharges, that pipelines may use to recoup infrastructure...more

11/24/2014 - EPA FERC Natural Gas Oil & Gas PHMSA Pipelines Power Infrastructure

Legal Alert: Crowley Marine Subsidiary Carib Energy Receives Authorization to Export LNG to Non-FTA Nations

Today, the U.S. Department of Energy (DOE) issued a final order authorizing Carib Energy (USA) LLC (Carib), a wholly-owned subsidiary of Crowley Marine, to export up to 400,000 gallons of LNG per day in ISO containers over a...more

9/11/2014 - DOE Energy Energy Policy Exports Free Trade Agreement Liquid Natural Gas

FERC Issues a NOPR Reforming Gas Day and Two Orders to Improve Natural Gas – Electric Generation Industry Coordination

On March 20, 2014, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) and two separate, but related, Orders to improve the coordination of scheduling natural gas pipeline capacity to...more

3/27/2014 - Energy FERC Natural Gas Utilities Sector

Legal Alert: New Regulation Under Cybersecurity Executive Order

President Obama yesterday issued an Executive Order to address the growing cyber threat to the Nation’s “critical infrastructure,” a term broadly defined to potentially cover natural gas and oil pipelines, storage sites and...more

2/13/2013 - Barack Obama Cybersecurity DHS Electricity Executive Orders Infrastructure Natural Gas

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