OUR ATTORNEYS

Susan Beall Kittey

Susan Beall Kittey
Susan Beall Kittey

Counsel

Counsel
P: (713) 338-3194
F: (713) 357-6776
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Susan’s principal area of practice is the regulation of natural gas, power, and liquid hydrocarbons, with a focus on energy markets and Federal Energy Regulatory Commission (FERC) enforcement matters. Susan has provided regulatory guidance for FERC enforcement matters including FERC Audits and Self-Reports. She advises clients on strategic and regulatory compliance matters, including those related to greenfield and brownfield liquids pipelines, working on numerous projects for the transportation of liquids from diverse supply areas. Susan also represents clients on a variety of regulatory matters associated with the transportation of natural gas by pipeline, including the abandonment of offshore facilities in a FERC proceeding. Prior to joining Caldwell Boudreaux Lefler PLLC, Susan was an attorney with the FERC’s Office of Enforcement where she investigated possible violations of statutes, rules and regulations, and orders by conducting depositions, interviews, and reviewing documents. Susan also served as a liaison between the Office of Enforcement and one of FERC’s organized energy markets.

Representative Experience

Liquids Pipelines

  • Assisted in the development of a FERC compliance program, including the drafting and implementation of compliance plans, policies, and procedures
  • Provided guidance on preparing for and undergoing a FERC audit, including assistance with data request responses and with preparation for a site visit by FERC staff
  • Managed the discovery matters related to a liquids pipeline proceeding at FERC
  • Assisted in the preparation of pre-filed testimony and pre-hearing/post-hearing briefs at FERC
  • Assisted in the preparation and drafting of transportation services agreements, tariffs, prorationing policies and similar documents associated with new and expanding liquids pipelines
  • Assisted in drafting petitions for declaratory orders before FERC related to new and expansion liquids pipeline projects to obtain FERC’s approval of the proposed terms and rate structures for such projects
  • Assisted in drafting and filing liquids pipeline tariffs with the FERC and state agencies
  • Provide regulatory guidance and analysis related to the operation of liquids pipelines regulated by the Railroad Commission of Texas, including issues regarding eminent domain, rights to change service, and compliance with regulatory filings

Natural Gas Pipelines

  • Assisting in the representation of an interstate natural gas pipeline with respect to its application for abandonment of offshore facilities
  • Providing regulatory guidance and analysis related to the acquisition of natural gas assets regulated by the Railroad Commission of Texas and compliance with applicable regulations
  • Assisted in providing guidance and analysis concerning the regulatory requirements for interstate and intrastate natural gas pipelines

Prior results do not guarantee a similar outcome.

Education and Professional Background
  • Presidential Management Fellow at FERC. During this two-year Fellowship, Susan worked in both the Office of Enforcement as an attorney and the Office of Energy Market Regulations as an economist
  • University of Virginia School of Law, J.D., 2011 (Virginia Environmental Law Journal, Development Editor)
  • Trinity University, B.A. in Economics (Concentration Theoretical Economics), magna cum laude, 2006 (Omicron Delta Epsilon (Economics Honor Society) Outstanding Senior Award)
  • Admitted to Practice: Texas, 2011
Activities and Affiliations
  • Energy Bar Association
Publications and Presentations
  • “Federal Energy Regulatory Commission Section 7 Certificate Process,” CLE Presentation, August 2017 (co-presenter)