Randy Rich
Elizabeth Acuna
202.828.5800 xTBD
Randall S. Rich represents all segments of the energy and utility industries before the Federal Energy Regulatory Commission (FERC), the United States Department of Energy (DOE), state public utility commissions (PUCs), and in appellate litigation. He provides comprehensive legal counsel on natural gas and oil pipeline regulation, ratemaking and tariffs, transportation matters and natural gas business transactions.
Mr. Rich counsels and advises on key energy industry issues, such as natural gas pipeline and storage certificates and tariffs, interstate pipeline capacity release and transportation, intrastate pipeline and storage rates and services, open access, compliance with the Natural Gas Act, Natural Gas Policy Act of 1978, and FERC regulations, transportation and storage contracts, natural gas gathering, open seasons for new projects and capacity, precedent agreements, Interstate Commerce Act, oil and products pipeline regulation, and DOE import and export authorizations.
Mr. Rich’s practice before state PUCs focuses on the competitive natural gas market, and on the establishment of gas transportation and retail electric competition programs that enable small industrial, commercial and residential energy consumers to choose their natural gas and power supplier. Mr. Rich also advises on state retail supplier certification and licensing.
Prior to joining the firm, Mr. Rich was a supervisory trial attorney with the FERC office of the general counsel.
Representative Matters
Represented natural gas marketers, a large independent producer, an intrastate pipeline, and an electric power producer in negotiation of precedent agreements and contracts for natural gas transportation and storage service on new facilities.
Representing developer of salt-dome natural gas storage facility in FERC certificate application, preparation of tariff and negotiation of precedent agreement and contract with anchor customer.
Black Marlin Pipeline Company, FERC Docket No. RP07-39-000. Representing Apache Corporation and ConocoPhillips Company in interstate pipeline rate case at FERC.
Eastern Shore Natural Gas Company, FERC Docket No. RP07-38-000. Representing the Premcor Refining Group (Valero Energy) in interstate pipeline rate case at FERC.
Represented Apache Corporation in obtaining FERC No Action Letter.
Represented major natural gas marketer in regulatory compliance and issues related to acquisitions of natural gas transportation, storage, and supply contracts from another marketer.
Represented developer of ethylene pipeline and storage facility in acquisition of facilities, preparation of tariff and Surface Transportation Board regulation under the Interstate Commerce Act.
Represented major natural gas marketers in capacity release and transportation issues.
Equitrans, L.P., FERC Docket No. RP04-203, et al., represented Independent Oil & Gas Association of West Virginia and Independent Oil & Gas Association of Pennsylvania in natural gas rate, gathering and certificate matters.
Enogex Inc., FERC Docket No. PR02-10, et al., represented Apache Corporation in intrastate pipeline rate proceeding.
MarkWest Michigan Pipeline Co. LLC, FERC Docket No. IS06-41-000, represented shipper of crude oil in FERC rate protest.
Represented energy companies in FERC enforcement investigations.
Default Service for Type II Standard Offer Service Customers, Maryland PSC Case 9037, represented Reliant Energy in hearing proceeding.
Represented Commerce Energy in state and federal licensing issues related to acquisition of another marketer.
Connecticut DPUC Case No. 05-05-10, represented Direct Energy Marketing in retail access hearing.
Publications and Speeches
Co-Author, "Natural Gas Gathering," Energy Markets and Transactions, 2003.
Speeches to independent natural gas producer client and major natural gas marketer client on compliance with FERC natural gas regulations, Houston, TX, October, 2006.
"Appalachian Gathering Update – The Equitrans Settlement," speech to Independent Oil & Gas Association of West Virginia Winter Meeting, Charleston, WV, February, 2006.
Education
J.D., Washington University School of Law in St. Louis, 1980
B.A., Brandeis University, 1977
Bar Admissions
District of Columbia
Missouri
Court Admissions
U.S. Court of Appeals for the 4th, 10th, 11th and District of Columbia Circuits
Affiliations
Energy Bar Association, Board of Directors, 2004-2007
Natural Gas Regulation Committee, Former Chair and Vice-Chair
FERC Practice and Administrative Law Judges Committee
Programs and Meetings Committee, Former Co-Chair
State Regulation Committee, 2005-2006
American Bar Association
Noteworthy
AV Rated by Martindale Hubbell