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Sandra E. Safro

Partner
+1.202.778.9178
Fax +1.202.778.9100
+1.713.815.7338
Fax +1.713.815.7301
Ms. Safro is a partner in the firm's Washington, D.C. and Houston offices and serves as a Practice Group Coordinator for the Oil, Gas, and Resources practice within the firm’s Energy, Infrastructure, and Resources practice group. She focuses her practice on regulatory, policy, and transactional issues related primarily to natural gas, liquefied natural gas (LNG), crude oil, and natural gas liquids (NGLs). Ms. Safro regularly advises clients on matters related to commodity and pipeline transportation issues, including the Federal Energy Regulatory Commission’s (FERC) policies related to capacity release and in the negotiation of precedent agreements, negotiated rate agreements, asset management arrangements, transportation service agreements, and the terms and conditions of service included in pipeline tariffs. Ms. Safro also advises clients on, issues related to the import and export of LNG, including commercial agreements related to terminal capacity, developments on Capitol Hill, and proceedings before FERC and the Department of Energy (DOE). She represents clients in natural gas and oil pipeline rate proceedings before the FERC and state agencies and advises clients on pipeline safety issues before the Pipeline and Hazardous Materials Safety Administration (PHMSA).

Ms. Safro’s clients include natural gas and LNG marketers, importers, exporters and project developers; oil pipelines and shippers; oil and gas drilling companies; financial institutions; and state and provincial government officials. She is also on the firm’s Women in the Profession Committee and chairs the Hiring Committee for the Washington DC office.

Professional Background

Prior to joining K&L Gates, Ms. Safro was a member of the energy and environmental practice group at a Washington, D.C. law firm. She worked in the compliance department of an energy trading company during a secondment in 2012.

Achievements

  • Named to “Best Lawyers - Energy Regulatory Law” in the 24th Edition (2018) and 25th Edition (2019) of the Best Lawyers in America
  • Selected as a “Rising Star” in Energy by the 2016 and 2017 editions of Super Lawyers
  • Named to “Trending 40’s Top Lawyers Under 40” in 2016 by Legal Bisnow

Professional/Civic Activities

  • Energy Bar Association, Board Member, 2016-2019
  • Charitable Foundation of the Energy Board Association, Board Member, 2014-2015
  • Energy Bar Association, Young Lawyers Committee, Vice Chair, 2013-2014

Speaking Engagements

  • Speaker, “Midstream Update, Challenges and the Real World,” Midstream PA 2017, October 19, 2017
  • Moderator, “Pipeline Development Disputes: Where is the Litigation Taking Us?” Shale Insight 2017, September 27, 2017
  • Speaker, “Pipeline construction continues – Or not,” Kallanish North America Oil & Gas 2017, May 23, 2017
  • Speaker, “The Criminalization of Environmental Regulation: How to Respond and is There More to come?” K&L Gates, February 28, 2017
  • Speaker, “The Sky’s the Limit: Unmanned Aircraft in the Natural Gas Industry,” Shale Insight 2016, September 21, 2016
  • Speaker, “Not in My Backyard - NIMBY Issues Facing Energy Infrastructure Projects,” E4 Carolinas, September 15, 2016
  • Speaker, “From Shale to Sail, Production, Transportation, and Export of U.S. Oil and Gas,” American Bar Association, Section of Environment, Energy, and Resources, April 1, 2016
  • Panel Moderator and Speaker, “Congressional Briefing on U.S. Liquefied Natural Gas Exports to India,” USINPAC, July 30, 2014
  • Speaker, “Fossil Fuel Exports,” University of Pittsburgh School of Law, 2013 Energy Law Policy Institute, August 1-2, 2013
  • Panel Moderator, “Pipeline Planning, Permitting, Construction, and Operation,” University of Pittsburgh School of Law 2013, Energy Law Policy Institute, August 1-2, 2013
Natural Gas Supply and Transportation
  • Perform due diligence related to sales of natural gas trading books, including review of key commercial provisions, verification of compliance with Federal Energy Regulatory Commission’s (FERC) regulations and policies, and submission of application for and receipt of waiver of FERC’s tying prohibition to effectuate the sales.
  • Negotiate commercial agreements for natural gas marketers, liquefied natural gas (LNG) exporters, and utilities to facilitate transportation of new unconventional natural gas supply to consuming markets including NAESB natural gas supply agreements, pipeline service agreements, precedent agreements, and asset management arrangements (AMA).
  • While seconded to compliance department of energy trading company, provided advice to natural gas traders and company on a daily basis concerning a variety of issues including vetting potential projects for FERC compliance issues, assisting company in reports to FERC and Department of Energy's (DOE), and responding to general compliance inquiries related to potential trades.
  • Negotiate precedent agreements for shippers including major LNG export project developer, electric power cooperative, and major NOC.
  • Assist clients with interstate natural gas and oil pipelines’ operations and policies before the FERC.
  • Represent clients in FERC Section 4, limited Section 4, and Section 5 rate proceedings and proceeding related to the terms and conditions of service on interstate natural gas pipelines.
  • Represent clients in FERC Section 7 proceedings for authorization for construction of new interstate natural gas pipeline facilities.
  • Assist clients with FERC Form No. 552 for natural gas purchasers and sellers.
  • Advise clients on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Part 192 regulations related to the transportation of natural gas by pipeline.
  • Advise clients on state registration requirements for natural gas marketers and brokers.
  • Negotiate and review contracts for the provision of natural gas and power service to residential customers.
LNG Terminals
  • Advise clients on U.S. federal, state and local authorities’ roles in the development of energy infrastructure, including pipelines and LNG terminal siting.
  • Assist clients with LNG import and export issues, including the DOE regulation of imports and exports of LNG, and the FERC regulation of LNG terminal facilities.
  • Provide strategic advice to LNG project terminal developers on issues of interagency coordination including FERC, PHMSA, EPA, OSHA, and FAA.
  • Negotiate commercial agreements related to LNG export terminal facilities and upstream natural gas pipelines, including Interconnect Agreements.
  • Advise clients on potential risks and liabilities associated with DOE reporting requirements for LNG exporters and their customers, including DOE penalty authority and commercial risk.
  • Assist major US LNG trade association in drafting comments on DOE’s May 2017 review of its regulatory requirements applicable to LNG exports.
  • Assist leading US LNG trade association in drafting reply comments on DOE’s 2012 LNG Export Study.
  • Advise clients on safety regulations under PHMSA, Part 193, applicable to LNG storage facilities and LNG transfer pipelines.
Oil and Products Pipelines
  • Negotiate transportation service agreement (TSA) and tariff language for shipper on new-build FERC-jurisdictional crude oil pipeline.
  • Assist project developers and potential customers in jurisdictional analysis for crude oil and natural gas liquids (NGL) pipelines.
  • Assist crude oil and NGL pipeline operator in Ukraine with drafting form TSA.
  • Advise clients on PHMSA Part 195 regulations applicable to the transportation of hazardous liquids by pipeline.