Randall S. Rich
Partner
Randall Rich is the partner-in-charge of the Washington, DC office. Throughout his over 40 years of experience, beginning in the Office of General Counsel of the Federal Energy Regulatory Commission (FERC) and continuing for more than 23 years at the DC office of a large Texas law firm, Randy has always strived to form close personal bonds with clients as well as trusting relationships with both regulators and his colleagues in the energy bar. He gains an intimate understanding of the business and legal needs of clients by working for extended periods in their offices, hand-in-hand with in-house counsel. Randy guides clients through the rapidly changing regulation of the natural gas and oil industry at the federal and state level, providing sophisticated counseling and representation in contested proceedings, multiparty settlements, applications, rulemakings, and enforcement investigations.
Randy represents all segments of the energy and utility industries before FERC, the U.S. Department of Energy, and state public utility commissions. He provides comprehensive legal counsel on natural gas regulation and policy, pipeline and utility ratemaking, tariffs, certificates and abandonment; natural gas transportation, gathering, marketing and trading; Natural Gas Act exemptions for Hinshaw pipelines, production and gathering, and plant lines; enforcement of and compliance with the Natural Gas Act (NGA), Natural Gas Policy Act of 1978 (NGPA), and FERC regulations; natural gas business transactions; Presidential Permits for cross-border facilities; renewable natural gas transactions; and oil pipeline regulation and waivers under the Interstate Commerce Act (ICA).
Since joining Pierce Atwood as a partner in the Energy Practice Group in 2009, Randy has worked with the firm's natural gas, oil, and petroleum products clients before FERC and in related matters, including marketer/trader, producer and end-user clients and New England-based gas pipelines, LDCs and end-users with a significant and growing interest in natural gas, renewable natural gas project developers, and crude oil and products producers, shippers and pipeline owners. He also has worked with consultants to foreign governments to draft new natural gas laws.
His long-time representation of the Gas and Oil Association of WV (formerly Independent Oil & Gas Association of West Virginia) and the Pennsylvania Independent Oil & Gas Association gives Randy keen insight into the development, production, and marketing of Marcellus and Utica shale natural gas, a game-changing supply of clean, strategically located domestic fuel that will power the eastern United States for the next century.
- Included in The Best Lawyers in America® for Energy Law, Energy Regulatory Law, and Oil and Gas Law (2020-present)
- The Best Lawyers in America® “Lawyer of the Year” in Washington, D.C. for Energy Regulatory Law (2022)
- Recognized by Chambers USA since 2009 as a leading lawyer in Nationwide Energy: Oil & Gas (Regulatory and Litigation), and since 2017 in Chambers Global in the same category
- Rated AV® Preeminent™ 5.0 out of 5 by Martindale-Hubbell
- Recognized as a Washington DC Super Lawyer in the area of Energy and Natural Resources (2014-2020)
- Energy Bar Association (1986-present): Masters Council 2020-present (co-chair 2022-24); Board of Directors, 2004-2007; Member, Natural Gas Regulation Committee (Natural Gas, Oil & Liquids Steering Committee), 2014-present; FERC Practice Committee, 2015-2019; Organizing Committee for Enforcers and Defenders Forum, 2016-2020
- American Bar Association, 1986-2020
- Gas and Oil Association of WV (formerly Independent Oil & Gas Association of West Virginia, Inc.), 1986-present
- Principal author, Energy Law & Transactions, Natural Gas Gathering Chapter (LexisNexis 2025)
Speaking Engagements
- Panel moderator, Maine Natural Gas Conference (October 2017-2019)
- Speech to Independent Oil & Gas Association of West Virginia, Inc. Winter Meeting (January 2020)
- Speech to Independent Oil & Gas Association of West Virginia, Inc., FERC Gas Transportation 101 (April 2017)
- Panel moderator, Energy Bar Association Enforcers and Defenders Forum (April 2017)
- Speech to Maine Natural Gas Conference (October 2016), regarding natural gas supply
- Speech to Independent Oil & Gas Association of West Virginia, Inc. Summer Meeting (August 2016), regarding recent developments at the FERC of interest to IOGA's Appalachian natural gas producer and marketer members. Randy serves as FERC and Washington, DC counsel to IOGA
- Speech to Maine Natural Gas Conference (October 2015), regarding gas service to industrial end users
- Speech to University of Texas School of Law 14th Annual Gas and Power Institute (September 2015), regarding key FERC orders in the past year
- Speech to Energy Bar Association Annual Meeting (June 2015), regarding "The FERC Way," and participated on a panel discussing steps practitioners should take to preserve arguments and appellate rights in FERC proceedings
- Pierce Atwood Pro Bono Committee (2014-present)
- Pierce Atwood Diversity, Equity & Inclusion Committee (2022- present)
- GeoPlunge "Coach," Patterson Elementary (DC), Anne Beers Elementary (DC) (2013-present)
- Anne Beers Spelling Bee pronouncer (2017, 2019, 2023)
- Member, 40th Reunion Committee, Brandeis University Class of 1977, after-dinner speaker (2017)
- Ladue (Mo.) Education Foundation - participated in a mock debate at event honoring former Horton Watkins (Ladue) High School Debate Coach and English Teacher, Wild Bill Heyde (2015)
- Washington Lawyers' Committee for Civil Rights and Urban Affairs (2004-present)
- Alumni speaker, Practicing in Washington, DC, 30th Reunion, Washington University School of Law (2010)
Practice Areas
- Represented informal coalitions of producers, associations, and marketers in settling several FERC natural gas pipeline rate cases. (2020-present)
- Representing Canadian LDC in US natural gas pipeline rate settlement. (2025)
- Represented major Canadian oil producer in Enbridge (Lakehead) oil pipeline rate case. (2021-24)
- Advise large natural gas marketers on FERC capacity release rules and policies, including buy/sell restrictions. (2022-present)
- Represented retail natural gas marketer in Massachusetts Department of Public Utilities Natural Gas Collaborative. (2022)
- Represented retail gas marketer in licensing, merger, and transfer of customers before Maryland, Pennsylvania, New Jersey, and New York regulatory commissions. (2024-25)
- Represented Northern Utilities d/b/a Unitil in obtaining Natural Gas Act Section 7(f) service area determination. (2023-24)
- Represented Northern Utilities d/b/a Unitil in interconnection negotiations with interstate pipeline. (2024)
- Representing Northern Utilities d/b/a Unitil and Bangor Natural Gas in renewable natural gas interconnection and contracting issues. (2024-25)
- Advised oil producer/gatherers on waivers of FERC regulation under Interstate Commerce Act. (2021-22)
- Representing oil refiner/shipper in Pennsylvania PUC and FERC tariff proceedings regarding reversal of flow. (2025-present)
- Advise natural gas pipeline operator and end user on FERC’s “plant line” exemption to regulation under the Natural Gas Act. (2021-present)
- Successfully obtained a Presidential Permit from the U.S. Department of Energy for the New England Clean Energy Connect electric transmission project. (2017-21)
- Represented Northern Utilities, Inc. d/b/a Unitil and Bangor Natural Gas Company in FERC proceeding regarding Atlantic Bridge natural gas pipeline project and continued operation of the Weymouth Compressor Station. (2021-23)
- Represented producer associations in FERC abandonment proceeding seeking to physically abandon pipeline facilities used by producers to deliver natural gas to markets. (2020-24)
- Representing producer associations in FERC rate case and settlement negotiations affecting sale of pipeline facilities used by producers to deliver natural gas to markets. (2020-present)
- Successfully obtained waivers of FERC’s natural gas transportation rules and policies to facilitate the sale of an interstate natural gas pipeline and associated producing properties and transportation capacity. (2020-present)
- Represented developer of renewable natural gas project in interconnection and downstream transportation issues, including Natural Gas Act 7(f) issues and Illinois Commerce Commission issues. (2022-24)
- Represented Gas and Oil Association of WV in judicial review of Mountain Valley Pipeline’s FERC certificates in US Court of Appeals for DC Circuit. (2021-24)
- Represented oil producers in open seasons for new crude oil pipeline facilities. (2024-25)
- Advised oil producer regarding appeal of Dakota Access Pipeline’s permitting. (2020-22)
- Represented Northern Utilities, Inc. d/b/a Unitil in settlement of Maritimes & Northeast Pipeline FERC rate case. (2024)
- Advising shippers and other parties on natural gas pipeline interconnection agreements. (2020-present)
- Successfully structured and obtained abandonment by sale from Greylock Pipeline to Greylock Shawville Pipeline to place interstate natural gas pipeline assets into a stand-alone special-purpose entity. (2020)
- Represented Granite State Gas Transmission in a successful pre-filing settlement of FERC transportation rates and future capital cost recovery. (2024)
- FERC Natural Gas Transportation Compliance Training for natural gas marketers. (2005-present)
- Represented Independent Oil & Gas Association of West Virginia, Inc. and Pennsylvania Independent Oil & Gas Association in negotiating a revised gas quality settlement with Texas Eastern Transmission. (2016)
- Advised potential LNG customer on contracts for new LNG facility. (2020-21)
- Advised oil and gas producer on jurisdiction of facilities to gather natural gas and to deliver gas to a sand plant by non-jurisdictional plant line. (2020)
- Represented Greylock Pipeline in obtaining certificate authorization under Section 7(c) of the Natural Gas Act from FERC to permit the transfer of Greylock Pipeline's interstate pipeline assets to a new entity, Greylock Shawville Pipeline. (2018-19)
- Represented Greylock Pipeline in prior notice filing under its FERC blanket certificate to authorize the acquisition of a 3-mile lateral connected to the pipeline. (2018-19)
- Represented a Maine-based pulp and paper mill in negotiating agreements to be a firm shipper on a new natural gas pipeline project. (2018-19).