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REPRESENTATIVE EXPERIENCE

Sandra E. Safro

Negotiate and review contracts for the provision of natural gas and power service to residential customers.
Assist leading US LNG trade association in drafting reply comments on DOE’s 2012 LNG Export Study.
Assist clients with FERC Form No. 552 for natural gas purchasers and sellers.
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 rep
Assist crude oil and NGL pipeline operator in Ukraine with drafting form TSA.
Advise clients on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Part 192 regulations related to the transportation of natural gas by pipeline.
Assist project developers and potential customers in jurisdictional analysis for crude oil and natural gas liquids (NGL) pipelines.
Advise clients on safety regulations under PHMSA, Part 193, applicable to LNG storage facilities and LNG transfer pipelines.
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.
Advise clients on state registration requirements for natural gas marketers and brokers.
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.
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.
Assist client in participation in FERC hydropower proceeding
Advise clients on U.S. federal, state and local authorities’ roles in the development of energy infrastructure, including pipelines and LNG terminal siting.
Negotiate renewable natural gas interconnect agreement between utilities and renewable natural gas producers
Assist clients with interstate natural gas and oil pipelines’ operations and policies before the FERC. Negotiate transportation service agreement (TSA) and tariff language for shipper on new-build FERC-jurisdictional crude oil pipeline.
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.
Advise clients on PHMSA Part 195 regulations applicable to the transportation of hazardous liquids by pipeline.
Assist major US LNG trade association in drafting comments on DOE’s May 2017 review of its regulatory requirements applicable to LNG exports.
Negotiate commercial agreements for natural gas marketers, producers, 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, interconnect agreements, and asset management arrangements (AMA).
Represent clients in FERC Section 7 proceedings for authorization for construction of new interstate natural gas pipeline facilities.Provide strategic advice to LNG project terminal developers on issues of interagency coordination including FERC, PHMSA, EPA, OSHA, and FAA.
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