We successfully obtained from the Federal Energy Regulatory Commission (FERC) two key waivers of its capacity release rules for a large independent oil and gas producer client. FERC requires that shippers on natural gas pipelines that seek to transfer pipeline capacity in connection with a large transaction or exiting the natural gas supply business seek a waiver of the capacity release rules and policies to ensure that there are no inadvertent violations.
The first waiver involved a release of capacity on an interstate pipeline from a natural gas gatherer/processor to move our client’s gas from the processing plant tailgate to an intrastate pipeline. The second waiver facilitated the release of capacity required by a corporate restructuring, in which three affiliates – formed when our client acquired another independent Permian Basin oil and gas producer – were rolled into our client. The client was pleased with the speed and ease of obtaining the waivers.