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Pamela J. Anderson

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Profile photo for Pamela J. Anderson
Partner

Pamela J. Anderson

With more than 25 years of experience in energy regulatory proceedings, litigation, and policy, Pam's practice has evolved to focus on renewable fuels and climate change issues.

Pam Anderson's clients include natural gas and electric utilities, rural cooperatives and municipalities, pipeline and storage companies, renewable energy developers, hydropower producers, oil and gas producers, and large consumers of energy resources throughout the country. She represents clients before various state utility commissions, the Federal Energy Regulatory Commission, the North American Electric Reliability Corporation, the Commodity Futures Trading Commission, and the U.S. Department of Energy.

Knowledgeable on utility rate and prudency issues, climate change and sustainability matters, and energy policy and rulemakings, Pam counsels clients on energy infrastructure and transaction issues, affiliated interest transactions, presidential permits, electric reliability, Dodd-Frank compliance, energy efficiency, and conservation rules, as well as investigations and enforcement proceedings. She also advises companies on drafting and negotiating energy transactions, including power purchase agreements, natural gas and pipeline capacity procurement, biomethane and renewable natural gas agreements, infrastructure agreements, and the purchase and sale of environmental attributes.

Education & Credentials

Education

  • University of Denver Sturm College of Law, J.D., 1989
  • University of Northern Colorado, B.S., Accounting, 1982

Bar and Court Admissions

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

Related Employment

  • Van Ness Feldman, Member; Seattle, WA and Washington, D.C.

Professional Recognition

  • Ranked in Chambers USA as “America’s Leading Lawyers" for Energy and Natural Resources Band 1 in Washington, 2021-2024

  • Listed in Best Lawyers in America: CleanTech Law; Energy Law; Energy Regulatory Law; Oil and Gas Law, 2013-2024

  • Named Best Lawyers' Seattle, "Energy Law Lawyer of the Year," 2017; "Energy Regulatory Law Lawyer of the Year," 2021, 2024

Impact

Professional Leadership

  • American Bar Association
  • Energy Bar Association, Past President, Western Chapter
  • Washington State Bar Association
  • Washington Clean Technology Alliance, Events Committee Member, 2017-2022
  • Charitable Foundation of the Energy Bar Association, Board Member, 2012-2014

Community Involvement

  • Eastside Legal Assistance Program, Board of Directors, 2020-present
  • Seafair, Board of Directors, 2013-present
  • Hearing, Speech & Deafness Center, Board of Directors, 2011-2017

Professional Experience

Experience

Utility Regulatory Proceedings

Represent local distribution companies (LDCs), electric utilities, pipelines and large energy users in rate cases, certificate proceedings and prudence reviews at FERC and before state utility commissions.

Utility Tariffs

Review and assist gas and electric utilities and oil and gas pipelines in preparing proposed tariff changes and defend against protested tariff change filings.

Renewable Energy

Counsel utilities and project developers on the sale or purchase of renewable energy projects, renewable natural gas, renewable energy credits and other types of environmental attributes, including due diligence and federal and state regulatory compliance.

Pipeline Open Seasons

Counsel pipelines and shippers in preparing open season materials and responding during the open season process. Also assist with drafting and negotiating precedent agreements.

Regulatory Compliance

Conduct comprehensive compliance reviews, develop compliance programs and procedures, and prepare and perform compliance training concerning FERC and state utility regulations.

Compliance Counseling

Counsel clients regarding energy compliance issues, including Dodd-Frank requirements, FERC’s rules concerning standards of conduct (SOC), market manipulation, code of conduct, price reporting, open access transmission requirements, internal accounting and the Uniform System of Accounts, and records retention. Also assist in establishing appropriate internal controls, procedures and training.

FERC Enforcement

Represent clients in all aspects of non-public FERC enforcement proceedings, including calls to the FERC Hotline, responding to calls to the FERC Hotline, preparing “no-action” letter requests, performing internal investigations, which may lead to self-reports, and responding to staff investigations.

Interconnection Negotiations

Counsel utilities and utility customers regarding FERC generator interconnection rules. Also assist in drafting and negotiating system impact study agreements, facilities study agreements and interconnection agreements.

Power Purchases

Represent electric companies and project developers in negotiations of power purchase agreements, including due diligence and regulatory compliance.

Electric Reliability

Represent owners or operators of the bulk-power system in their efforts to comply with reliability standards enforced by the North American Electric Reliability Corporation (NERC) and regional reliability entities.

Interstate Commerce Act Counseling

Counsel oil pipelines and shippers in all aspects of FERC regulation and common carrier obligations under the Interstate Commerce Act.

FERC Proceedings for Oil Pipelines

Successfully represent oil pipelines in protested index-rate proceedings, and litigated cost-of-service and market-based rate proceedings.  Represent shippers and pipelines in complaint proceedings, including settlement judge proceedings and using the FERC alternative dispute resolution service.

Representative Matters

  • Secured state regulatory approval for an LNG storage facility to serve utility peaking and maritime fuel needs.
  • Represented an electric cooperative intervenor in various state rate case proceedings, including cases filed by a transmission pipeline, a distribution pipeline and a natural gas storage company.
  • Successfully defended against a request for advance determination of prudency for redundant facilities.
  • Secured state regulatory approval of pipeline tariff provisions governing acceptance of renewable natural gas.
  • Represented an electric utility in converting a power purchase agreement to the joint purchase of a 130 MW wind farm.
  • Represented an electric utility in developing power purchase agreement templates for solar and solar + storage purchases.
  • Counseled a natural gas utility in negotiating agreements for renewable natural gas injection and in purchasing and selling renewable natural gas and environmental attributes.
  • Represented a local distribution company and an electric utility in rate case settlements with interstate natural gas pipelines.
  • Advised a local distribution company in negotiating lateral facility expansion agreements with interstate natural gas pipeline.  
  • Secured approval of a Presidential Permit for natural gas import facilities.
  • Advised a lighting manufacturer and distributor concerning compliance with DOE energy efficiency regulations.
  • Advised a refiner in negotiating and drafting a settlement agreement with a pipeline concerning transportation and transmix recovery fees.
  • Assisted an oil pipeline in filing rate change tariffs at the FERC and the Regulatory Commission of Alaska.
  • Assisted an oil pipeline in bringing its FERC reporting issues current and achieved a successful outcome from a self-report of the issue to FERC Enforcement.
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