James "Gus" Howard focuses his practice on federal regulation of the interstate natural gas industry. He is experienced in natural gas pipeline rate and certificate matters under the Natural Gas Act (NGA) before the U.S. Federal Energy Regulatory Commission (FERC) and before the federal courts of appeals on review of orders of the FERC.
While at the firm, Gus has advised clients in matters involving the exportation of natural gas at FERC and at the Office of Fossil Energy of the Department of Energy. He has assisted in several interstate pipeline rate cases before FERC and on review by the courts of appeals. He has been extensively involved in efforts to establish a system to bring to market Alaska North Slope natural gas reserves. He has assisted in matters arising before state regulatory agencies. Additionally, Gus has assisted clients with issues arising under the National Environmental Policy Act and the regulations of the Council on Environmental Quality. He has participated in due diligence efforts involving acquisitions of FERC-licensed hydroelectric projects and efforts to secure authorization, under the Federal Power Act, to sell FERC-jurisdictional electrical utility assets.
Prior to joining the firm, Gus was counsel at two prominent Washington, D.C. law firms where he concentrated on federal regulation of natural gas. Before that, he provided FERC representation for The Coastal Corporation's interstate pipelines, principally those operating in the Rocky Mountains region. In that capacity, Gus was responsible for numerous rate change filings under Section 4 of the NGA and for applications for certificates of public convenience and necessity under Section 7 of the NGA, seeking authorization for large-scale expansions of jurisdictional systems, for the creation of a natural gas storage company, and for the transfer of CIG's gathering properties to an unregulated affiliated corporation. Previously, he served in a similar capacity with Tenneco Gas Pipeline Group (formerly Tennessee Gas Transmission Company), where Gus litigated the "Tennessee Exchange" case before the Fifth Circuit. There, he assisted Tennessee Gas in the interstate pipeline “take-or-pay” litigation in the early to mid-1980s.
Preceding his service in the legal departments of interstate pipelines, Gus was affiliated with a Washington, D.C. law firm where he litigated before FERC and before federal courts. He participated in natural gas curtailment cases, wholesale electric cases before FERC and on review to the courts of appeals, and in electric utility antitrust cases before the federal district courts and courts of appeals.