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Pamela Tsang Wu

Associate

Washington, DC Phone +1.202.739.5199 Fax +1.202.739.3001

1111 Pennsylvania Ave. NW//Washington, DC 20004-2541//United States

Pamela T. Wu advises clients in the natural gas, oil, and electric power industries before the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the US Department of Transportation, and the Texas Railroad Commission on rate, regulatory, and transactional matters. Pam represents clients in administrative litigation before FERC in rate and tariff proceedings and advises clients on compliance with the Natural Gas Act, the Interstate Commerce Act, and FERC-regulated tariffs. 

Pam also advises clients seeking to acquire or divest electric, natural gas, and renewable assets, as our clients look to attain net zero carbon emission goals. In addition, her practice focuses on FERC compliance and enforcement matters. Pam counsels clients in investigations conducted by the FERC and the CFTC. She has represented clients in nonpublic investigations and litigated proceedings at FERC that have alleged fraudulent or manipulative trading activity, violations of Independent System Operator or Regional transmission Organization rules, and violations of FERC’s market-behavior rules. She has also represented clients in CFTC investigations alleging fraudulent or manipulative trading of futures or derivatives products in violation of the Commodity Exchange Act. Additionally, Pam assists clients in developing and implementing effective compliance programs and counsels clients in FERC audits. 

In addition, Pam counsels clients on issues relating to the development of liquefied natural gas (LNG) terminal projects. She advises clients seeking to obtain import and export authorizations from the Department of Energy to export LNG and authorizations from FERC to construct and operate the liquefaction facilities.

Awards and Affiliations

Associates to Watch, Energy: Oil & Gas (Regulatory & Litigation), USA - Nationwide, Chambers USA (2021)

Member, Law Firm of the Year, Energy/Projects: Power (including Renewables), Chambers USA (2018)

Member, Practice Group of the Year, Energy, Law360 (2016, 2019)

Member, Energy Law Firm of the Year, US News & World Report/Best Lawyers (2015)

Member, Energy Bar Association

Note and comment editor, American University Law Review

Admissions

  • District of Columbia
  • Virginia
  • US Court of Appeals for the District of Columbia Circuit

Education

  • American University Washington College of Law, 2011, J.D.
  • University of Virginia, 2008, B.A.

Sectors

Services

Regions

Events

3/30/2022 - Natural Gas Infrastructure
12/9/2021 - Energy Markets and Commodity Trading Enforcement & Litigation: 2021 Year in Review
3/2/2021 - Coffee and Commodity Trading
7/13/2020 - Now. Normal. Next. An Energy Industry Webinar Series | Effective Compliance Oversight of Energy Commodity Trading in a Remote Trading Environment
3/4/2020 - Infocast's 23rd Annual Transmission Summit East
7/19/2018 - Navigating #MeToo Issues in the Energy Industry
4/12/2018 - Oil & Gas Regulatory Roundup – 1st Quarter 2018
1/11/2018 - Oil & Gas Regulatory Roundup – 4th Quarter 2017
10/11/2017 - Oil & Gas Regulatory Roundup – 3rd Quarter 2017
6/29/2017 - Oil & Gas Regulatory Roundup – 2nd Quarter 2017
4/12/2017 - Oil & Gas Regulatory Roundup – 1st Quarter 2017
1/11/2017 - Fourth Quarter Oil & Gas Regulatory Roundup 2016
11/29/2016 - Energy Storage: FERC’s Technical Conference & NOPR
10/11/2016 - Third Quarter Oil & Gas Regulatory Roundup 2016
9/21/2016 - Corporate Counsel Women of Color’s 12th Annual Career Strategies Conference
8/31/2016 - Qualifying Facilities and PURPA: FERC’s Reassessment After Nearly 40 Years
3/17/2016 - Renewable Energy and Storage Trends for 2016

News

10/27/2016 - Morgan Lewis Releases FERC Compliance: A Legal and Business Guide

Publications

5/13/2022 - The Growth and Development of Carbon Offset Markets
4/26/2022 - FERC Investigates Five Western Utilities’ Formula Rate Protocols
3/9/2022 - FERC Turns Its Enforcement Efforts Toward Infrastructure Development
12/28/2021 - District Court Ruling Would Impute Liability to Employer in Nearly All FERC Enforcement Matters
12/27/2021 - FERC Issues Show Cause Orders to Two Natural Gas Pipelines
12/3/2021 - Ohio District Court Rejects FERC Enforcement of Disgorgement and Joint and Several Liability
11/15/2021 - Bipartisan Infrastructure Bill Could Revolutionize the Energy Industry
11/12/2021 - Natural Gas Gathering Pipelines Subject to Federal Oversight by PHMSA
10/1/2021 - PJM’s ‘Focused’ Minimum Offer Price Rule Takes Effect by Operation of Law
9/15/2021 - Under New Chairman, FERC Refocuses Its Priorities for Natural Gas Pipeline Projects
6/21/2021 - FERC Notice of Inquiry on Policy Statement on Interstate Natural Gas Pipeline Proposals Draws Industry Comment
6/16/2021 - DOI Announces Proposed Lease Sale for Offshore Wind Development for New York and New Jersey
6/10/2021 - FERC Reaffirms Commitment to Aggressively Investigate and Penalize Fraud and Manipulation
5/20/2021 - FERC Reaffirms Commitment to Aggressively Investigate and Penalize Fraud and Manipulation
May 2021 - Regulating US LNG Projects, Practical Law Oil & Gas
3/30/2021 - FERC Proposes to Collect New Upstream Owner Data from Holding Companies of MBR Entities Holding Certain Blanket Authorizations
3/19/2021 - FERC Modifies Water Quality Certification Waiver Period for Gas Projects
2/19/2021 - FERC Focuses on Environmental Justice in Pipeline Certification Policy Statement
2/17/2021 - Glick Brings Environmental Justice to the Forefront
1/28/2021 - Energy and Climate Update: Day 7 of Biden’s Presidency
1/27/2021 - New Natural Gas Infrastructure Likely to Face Challenges During Biden Administration
12/29/2020 - Congress Updates US Energy Policy, Incorporates Energy-Related Tax Provisions Through Consolidated Appropriations Act, 2021
12/18/2020 - FERC Proposes Revisions to Its Price Index Policy to Encourage Price Reporting
October 2020 - Now. Normal. Next. Effective Compliance Oversight of Energy Commodity Trading in a Remote Trading Environment, Pratt’s Energy Law Report
6/12/2020 - Effective Compliance Oversight of Energy Commodity Trading in a Remote Trading Environment
5/8/2020 - COVID-19: Treasury to Modify Continuity Safe Harbor for Production, Investment Tax Credits
5/6/2020 - COVID-19: PHMSA Discretion to Enforce Certain New Gas Pipeline Safety Regulations
5/4/2020 - CFTC Review of WTI Futures Contract Prices Captures Attention of Industry Market Participants
4/14/2020 - CARES Act: Treasury Identifies Businesses ‘Critical to Maintaining National Security’
3/31/2020 - CARES Act: Key Takeaways For Energy Companies
3/31/2020 - Energy Sector Impacts of the CARES Act
3/30/2020 (Updated 04/21/2020) - CARES Act: Key Takeaways for Energy Companies
3/27/2020 - PHMSA Notice to Operators: Stay of Enforcement and Enforcement Discretion for Certain Requirements Due to COVID-19
2/18/2020 - PHMSA Issues Final Rule on Underground Natural Gas Storage Facilities Safety
11/11/2019 - CFTC Awards $15 Million in Five Whistleblower Awards in 2019; Cumulative Awards Total $100 Million
10/28/2019 - CFTC Settles With Energy Company for Acting as an Unregistered Futures Commission Merchant
10/15/2019 - Executive Orders May Limit Effect of Agency Guidance Documents
6/25/2019 - FERC Must Explain Departure from Methodology for Evaluating Index Rate Increases
6/11/2019 - First Circuit to Consider FERC Filed Rate Doctrine Implications on Retail Energy Prices
June 2019 - FERC Clarifies Order No. 845’s Interconnection Reforms, Energy Law Report
5/16/2019 - FERC Rescinds Its Policy of Issuing Notices of Alleged Violations
4/30/2019 - Federal Courts Continue to Define State Permitting Authority Affecting Interstate Pipeline Projects
4/30/2019 - OMB Expands FERC Actions Subject to Prepublication Review
3/5/2019 - Calcasieu Pass Terminal Authorization Elevates Climate Change Concerns to the Forefront
3/5/2019 - FERC Clarifies Order No. 845’s Interconnection Reforms
7/12/2018 - LawFlash: PJM’s New Notice Requirement for Changes in Generation Ownership or Control
7/11/2018 - PJM Interconnection Implements New Requirements for Generator Interest and Asset Sales
7/2/2018 - DOE/FE Policy Statement Confirms Stability of Long-Term Non-FTA Export Authorizations
6/19/2018 - FERC Commissioners Explain Priorities, Respond to Trump DOE Directive
6/15/2018 - NRC, FERC Enter into MOU to Protect CEII
4/27/2018 - FERC Adopts Reforms to Address Inefficiencies in Interconnection Process
4/27/2018 - LawFlash: FERC Revises Generation Interconnection Process
12/6/2017 - DC Circuit Rejects Challenges to FERC’s 2015 Oil Pipeline Rate Index
11/3/2017 - Full Bench Restored at FERC
11/1/2017 - Swap Dealer De Minimis Threshold to Remain in Effect Through December 31, 2019
10/12/2017 - Reminder: Commitments in Precedent Agreements May Later Be Rejected by FERC
6/16/2017 - US Supreme Court Imposes Limitations on Disgorgement
6/9/2017 - Inside The CFTC's Enhanced Whistleblower Protections, Law360
2/2/2017 - Law360 Article: FERC Energy Storage Policy Faces Uncertainty Under Trump
1/27/2017 - FERC Energy Storage Policy Faces Uncertainty Under Trump, Law360
1/3/2017 - FERC Proposes Reforms to Generator Interconnection Process
12/20/2016 - PHMSA Sets Safety Standards for Underground Gas Storage Facilities
11/22/2016 - FERC Proposes to Integrate Electric Storage into Organized Markets
10/7/2016 - PHMSA Implements Authority to Issue Emergency Orders
9/12/2016 - Rise In Whistleblower Claims Likely With New CFTC Rules, Law360
9/2/2016 - CFTC Proposes Amendments to Whistleblower Awards Process and Anti-Retaliation Authority
7/27/2016 - Federal Court Grants Full Civil Trial to FERC Enforcement Target
11/24/2015 - FERC Terminates Proceeding That Would Increase Reporting of Natural Gas Sales
11/17/2015 - Retail Customers Can Challenge Transmission and Wholesale Power Sales Rates
6/25/2015 - Battery Energy Storage Facilities May Be Subject to Wholesale Distribution Charges
3/26/2014 - FERC Adopts Revisions to Bulk Electric System Definition
7/8/2013 - NERC Fines Generator for Violations Related to Lead Line Operations
3/19/2013 - FERC Lacks Authority Over Commodity Futures Contracts
2/19/2013 - D.C. Circuit Upholds FERC Ruling to Apply Mobile-Sierra Doctrine to FCA Rates
11/19/2012 - FERC Reframes Nexus Test for Transmission Incentives Applications
9/25/2012 - FERC Clarifies that a Utility May Not Curtail Unilaterally for Purchases from QFs Under a Long-Term Obligation
5/21/2012 - FERC Reiterates That It Lacks Authority to Compel Interconnection Between Oil Pipelines
4/17/2012 - LawFlash: FERC Approves LNG Export Project
4/17/2012 - FERC Approves LNG Export Project
3/16/2012 - FERC Proposes Changes to EQR to Improve Accuracy in Reporting Simultaneous Exchanges
2/21/2012 - Standards for Business Practices for Interstate Natural Gas Pipelines
2/10/2012 - Audit Evaluates Compliance with Accounting and Reporting Regulations
2/3/2012 - FERC Staff Proposes Process on Advising EPA on Extension Requests
1/30/2012 - FERC Eliminates Semiannual Natural Gas Storage Reporting Requirements
1/20/2012 - FERC Disclaims Jurisdiction Over Kenai Pipelines and Related Facilities
1/19/2012 - FERC Rejects Revised Tariff Provisions and Orders Filing of Revised Service Agreement When Provision Is Deemed Unduly Discriminatory
1/12/2012 - FERC Clarifies Information Required in Cost and Revenue Studies in NGA Section 5 Investigations
12/27/2011 - FERC Rejects Duke-Progress Merger Mitigation Plan
12/21/2011 - Reliability Technical Conference
12/8/2011 - FERC Finds Market Manipulation in ISO-NE
12/8/2011 - Commission Orders BPA to Provide Comparable Transmission Access
12/5/2011 - Technical Conference on Penalty Guidelines
10/27/2011 - Fifth Circuit Vacates Intrastate Pipeline Posting Requirements Under FERC Order Nos. 720 and 720-A
February 2010 - The Case Against "Bad Faith" Dismissals of Bankruptcy Petitions Under 11 U.S.C. § 707(a), American University Law Review, Vol. 59, No. 3.