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Glenn S. Benson

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Of Counsel

Glenn Benson focuses on providing solutions to regulatory challenges and issues faced by all segments of the energy industry, including electric power generators, marketers and distributors, natural gas developers, transporters and distributors, and petroleum production, transportation and sales. For more than 17 years, Glenn has advised and represented both large and small energy companies in every geographic region of the United States, much of Canada, and parts of Eastern Europe. His work includes:

  • Assisting and representing natural gas pipeline and storage project developers to obtain and comply with Federal Energy Regulatory Commission (FERC) certificates of public convenience and necessity. Glenn has worked on both "Greenfield" and expansion projects.

  • Advising and Representing renewable energy project developers and related interests with respect to power purchase agreements, interconnection agreements, tariff issues, renewable energy credits/certificates, meter service agreements, participating generator agreements, and regulatory proceedings before FERC and State public utility commissions.

  • Providing advice and representation to natural gas pipelines, as well as shippers on such lines, with respect to transportation service agreements, gathering agreements, processing agreements, and a variety of tariff and regulatory issues, including open access, blanket certificate authority, the rules governing Hinshaw pipelines and intrastate pipelines providing Section 311 service, tariff development, cost-of-service based rates, capacity release and assignments, gas quality and interchangeability standards, fuel charges, rights of first refusal and rollover/evergreen rights, credit requirements, segmentation, allocation of corporate overhead, NAESB standards, enhanced/hourly firm transportation rate schedules tailored for gas-fired electric generators, reporting requirements, interconnection policy, pipeline safety rules of the Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA), import authorizations, open access issues involving the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE), and the treatment of regulatory assets associated with levelized rate agreements.

  • Advising and representing power marketers on market rules and tariff proceedings involving PJM Interconnection, the Midwest Independent Transmission System Operator, the New York Independent System Operator, the California Independent System Operator, ISO New England, the Electric Reliability Council of Texas, and the Southwest Power Pool.

  • Providing advice and representation to crude oil and petroleum products pipelines, as well as shippers on such lines, with respect to rate cases and complaint cases before FERC and state regulatory commissions, obtaining waivers of tariff and reporting requirements for proprietary pipelines, tariff development, PHMSA pipeline safety requirements, proration policies, and throughput and deficiency agreements.

  • Providing advice and representation to onshore and offshore producers of oil and natural gas with respect to the negotiation of gathering agreements, pipeline transportation agreements, processing agreements, marketing agreements, dedications of reserves, regulatory rate cases before FERC and State Commissions, compliance with FERC's "shipper must have title" rule and prohibition on "buy sell" transactions, compliance with FERC reporting requirements, and contesting subpoenas of confidential information.
Glenn regularly provides advice and representation to companies across all segments of the energy industry regarding tariff issues, Independent System Operator rules, power purchase agreements, interconnection issues, contract issues, regulatory compliance, regulatory enforcement, jurisdictional issues, complaints, rate cases, and hydroelectric relicensing. Glenn routinely represents companies in contested electric utility, natural gas pipeline, and oil pipeline regulatory proceedings before the FERC and in alternative dispute resolution. Glenn also has significant experience advising clients with respect to carbon sequestration projects.

Glenn has substantial experience advising energy companies and financial institutions on federal and state energy regulatory issues that arise in connection with pipeline construction projects, mergers, acquisitions and divestitures in the natural gas and electric industries, joint ventures, pipeline service agreements, interconnection agreements, marketing agreements, financing and other commercial transactions. Glenn has experience in appellate litigation on review of decisions of the FERC and the Department of the Interior. In addition, he has experience in transactional matters involving the Public Utility Holding Company Act of 2005, in obtaining authorizations to import/export natural gas and electric power from the Department of Energy, in obtaining Presidential Permits for international electric transmission lines, and in obtaining authorizations for oil pipeline border crossing facilities from the State Department. He also has experience in Department of Transportation regulation of pipeline safety.

Professional Leadership

  • Board of Directors for the Foundation for the Energy Law Journal, 2005 - present
  • Energy Bar Association
    • Committee on Natural Gas Regulation, Vice-Chair, 2007 - 2008; Chairman, 2008 - 2009 
    • Committee on Oil Pipeline Regulation, Vice Chairman, 2003 - 2004; Chairman, 2004 - 2005
    • Natural Gas Pipeline Committee, 2000 - 2005
    • Electric Utility Regulation Committee, 2003 - 2005
    • Generation and Power Marketing Committee, 2002 - 2003
    • Finance and Transactions Committee, 2003 - 2004
    • International Energy Transactions Committee, 2003 - 2004
    • Antitrust Committee, 2003 - 2005
    • Alternative Dispute Resolution Committee, 2000 - 2001
  • Energy Law Journal, Business Manager, 2005 - present

Related Employment

  • Fulbright & Jaworski L.L.P., Washington, D.C., Senior Associate, 1998 - 2004; Senior Counsel, 2005 - 2008
  • Travis & Gooch, Washington, D.C., Associate, 1994 - 1998

Education

  • University of Virginia School of Law, J.D., 1993
    Editor, Virginia Journal of International Law; Chief Editor, Virginia Center for National Security Law
  • Syracuse University, A.B., magna cum laude; Phi Beta Kappa, 1990

Bar Admissions

  • District of Columbia
  • New York

Court Admissions

  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. District Court for the District of Columbia