Rabeha is a partner in Dorsey’s Regulatory Affairs group. She focuses her practice on energy regulation, compliance, and enforcement matters and represents clients before the Federal Energy Regulatory Commission (“FERC”) and state public utility commissions.
Rabeha has represented energy clients in all stages of the regulatory process and government investigations, including interstate oil and natural gas pipelines and storage providers, liquefied natural gas (“LNG”) exporters, public utilities, transmission owners, independent power producers, and state power authorities. She has assisted clients in oil/natural gas pipeline and electric utility infrastructure development, navigating open access policies, pursuing renewable power initiatives, pipeline and utility mergers and acquisitions, rates and services, and FERC compliance and enforcement rules and policies. In addition to federal agencies, Rabeha has represented clients before state and federal/appellate courts on energy regulatory matters.
- Represented interstate natural gas pipeline in relocation and abandonment project and FERC Certificate application.
- Represented U.S.-Canadian pipeline in proposed abandonment and termination of Section 3 authorization and Presidential Permit.
- Represented interstate oil pipelines before FERC and state commission regarding jurisdictional determination and proposed deregulation.
- Represented natural gas exporters in obtaining FERC and Department of Energy authorizations for constructing LNG export terminals and exporting LNG to overseas markets.
- Representing and advising public utilities on open-access policies and participation in energy markets, including Regional Transmission Organizations.
- Representing investors in the acquisition due diligence of a large-scale natural gas construction project.
- Represented public utility in formula rate transmission case (i.e., request for Order No. 679 rate incentives).
- Representing public utilities and renewable projects in obtaining and maintaining market-based rate and exempt wholesale generator authorizations, advising on affiliate restrictions, and Public Utility Holding Company Act of 2005 holding company issues.
- Representing public utilities in all aspects of FERC compliance and reporting obligations, including obtaining FPA 203 authorization for the acquisition of FERC jurisdictional facilities.
- Representing and advising public utilities in federal and state Public Utilities Regulatory Policies Act of 1978 (“PURPA”) enforcement cases, federal and state “avoided cost” proceedings, PURPA contract negotiation, and “legally enforceable obligation” proceedings.
- Representing public utility in negotiations involving the development of an international transmission line, including counseling on ownership structure and FERC jurisdictional issues.
- Represented public utilities and energy companies in the transfer of ownership interests in major electric, nuclear power and wind-powered generation facilities, including leading regulatory review and securing Federal Power Act (“FPA”) section 203 and state approvals.
- Represented commodity institution in its sale of power assets involving the largest bankruptcy proceeding in U.S. history, including securing FPA section 203 approval and counseling client on foreign investment issues in FERC-regulated projects.
- Represented various energy market participants in CFTC investigation involving allegations of market manipulation.
- Represented commodity institutions, oil producers, and oil/gas exploration companies in internal investigations involving fraud issues under the Foreign Corrupt Practices Act.
- Represented power trading firms in FERC and CFTC investigations involving allegations of fraud and disruptive trading.
- Represented project developer of renewable energy ventures in the development of a biomass power plant, including leading regulatory review and preparing project documents. The deal was awarded North American Mezzanine Financing Deal of the Year for 2011 by Project Finance Magazine.
- Represented crude oil refinery in acquiring oil storage terminal as part of a large-scale expansion of the refinery’s transportation network.
- Represented project developers of interstate natural gas storage, pipelines, and liquefied natural gas terminals, including pipeline developed to transport shale gas to market, in all aspects of FERC certificate, tariff and rate proceedings under the Natural Gas Act, and representation of the first two LNG projects in the lower-48 states proposing the export of domestically-produced LNG.
News & Resources
News & Press Mentions
- “Enforcement Workshops: Workshop II - Implementing an Internal Surveillance and Compliance Program and Conducting an Internal Investigation,” Dorsey & Whitney LLP, May 2014
- “Enforcement Workshops: Workshop I - Defending Against Multi-Agency Enforcement Actions,” Dorsey & Whitney LLP, May 2014
Industries & Practices
- Development & Infrastructure
- Electric Power
- Energy & Natural Resources
- Oil & Gas
Professional & Civic
- Energy Bar Association – Chair, Compliance and Enforcement Committee (2016-2017)
- South Asian Bar Association – North America – Co-Chair, Law Partners Section (2017-2018)
- South Asian Bar Association – DC Chapter – Mentoring Committee
- National Asian Pacific American Bar Association – Energy and Natural Resources Committee