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Mary Anne Sullivan
Partner, Washington, D.C.
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maryanne.sullivan@hoganlovells.com

Mary Anne Sullivan has more than 25 years of experience as an energy lawyer. During that time, she has had direct involvement with virtually every segment of the energy industry — electric, gas, oil, coal, nuclear, and alternative energy technologies. Likewise, she has represented clients on energy issues in administrative, regulatory, transactional, and litigation matters in both the private sector and the government. Her current practice includes electricity, nuclear, renewable energy, advanced energy technologies, biofuels, energy efficiency standards, and climate change matters. Lauded by Chambers Global, Mary Anne “is a vastly experienced energy attorney” and "well placed to advise clients on the major issues currently affecting the industry."

Mary Anne rejoined Hogan & Hartson in 2001 after serving as General Counsel of the U.S. Department of Energy (DOE) from 1998 to 2001 and as Deputy General Counsel for environment and nuclear programs from 1994 to 1998. During her government service, she provided advice and counsel to the DOE on such matters as electricity restructuring, the California electricity crisis, oil and gas policy, climate change, clean coal programs, radioactive waste disposal, nuclear safety regulation, and privatization of uranium enrichment activities. Mary Anne provided extensive legal support for the opening of the world's first deep geologic disposal facility for radioactive waste, and negotiated the first agreements with electric utilities regarding voluntary reductions of greenhouse gas emissions. She provided active legal oversight of one of the government's largest intellectual property programs, and a multibillion dollar government contracting program.

Before entering government service, Mary Anne was a member of Hogan & Hartson's energy group from 1977 through 1993. She represented oil, gas, coal, and electricity interests principally before the DOE, U.S. Department of the Interior, U.S. Department of Treasury, and the Federal Energy Regulatory Commission in related litigation. She also provided advice and counsel on environmental issues to the chemical, electronics, and automotive industries.

Mary Anne is a frequent public speaker and is the author of numerous articles on a variety of energy and environmental law topics. She has testified before several congressional committees on nuclear safety regulation, whistleblowers, environmental management, and other issues. She was a senior lecturer in law at Duke University Law School during the spring 2004 semester, and she was a professorial lecturer in law at George Washington University Law School for the fall 2006 semester, teaching energy law.  

REPRESENTATIVE EXPERIENCE
  • Representing the developer of a major new electric transmission project in a Presidential Permit proceeding before DOE.
  • Advising several appliance manufacturers in connection with issues arising under DOE efficiency standards.
  • Advising developers of small modular reactors on matters relating to federal funding, nuclear export controls and related matters.
  • Advising nuclear clients on issues relating to the regulation of foreign ownership, control and influence by DOE and NRC, Price Anderson and security matters.
  • Advising oil and gas clients on pipeline safety regulatory and carbon capture and storage for enhanced oil recovery.
  • Representing clients in DOE and USDA loan guarantee and grant matters.
  • Representing electric clients in litigation before FERC.
  • Advising clients in carbon trading and Renewable Energy Certificate transactions.
  • Advising clients in connection with funding for and deployment of new energy technologies.
  • Advising clients on issues relating to alternative energy sources, including wind development, ethanol, biomass and hydrogen fuel, climate change, and renewable portfolio standards.
  • Assisting clients with contracting issues at DOE, including competitive procurements, bid protests, contract performance, indemnification for nuclear accidents, and termination issues.


Hogan Lovells Publications
10 September 2014 "FERC Largely Disclaims Jurisdiction Over Certain LNG Project Facilities; Incoming Chairman Bay Dissents in Part." Energy Alert, Hogan Lovells

07 May 2014 "DoD Adopts Final Rule Clarifying Photovoltaic Device Rules of Origin." Energy Alert, Hogan Lovells

25 March 2014 "FERC Initiates Rulemaking to Align Natural Gas Pipeline Scheduling and RTO and ISO Generation Dispatch Times and Enhance Flexibility of Pipeline Services." Energy Alert, Hogan Lovells

11 March 2014 "NERC on Short Deadline to Develop Physical Protection Standards." Energy Alert, Hogan Lovells

06 November 2013 "Summary and Analysis of United States v. Duke Energy Corp. (M.D.N.C. 6 Nov. 2013)." Energy Alert, Hogan Lovells

25 October 2013 "New IRS/Treasury Guidance on the Production Tax Credit for New Nuclear Facilities." Energy Alert, Hogan Lovells

10 October 2013 "Energy Agencies Face Different Fates in Government Shutdown." Energy Alert, Hogan Lovells

05 August 2013 "Department of Energy issues revised proposed rulemaking regarding its nuclear export control regulations." Energy and Export Controls Alert, Hogan Lovells

12 July 2013 "DOE seeking comments on advanced fossil loan program." Energy Alert, Hogan Lovells

17 June 2013 "DOE issues Proposed Rule to impose export control compliance requirements for contractors." Export Controls Alert, Hogan Lovells

07 June 2013 "NRC issues order designating first group of facilities eligible to apply for Section 161A weapons preemption authority." Energy Alert, Hogan Lovells

14 February 2013 "Focus on Gun Control May Make NRC Licensees Focus on 161A." Energy Alert, Hogan Lovells

29 May 2012 "How will FERC advise the EPA on the reliability impacts of MATS compliance?" Energy Alert, Hogan Lovells

21 March 2012 "FERC approves streamlined NERC “Find, Fix, Track” enforcement process." Energy Alert, Hogan Lovells

07 March 2012 "DOE announces US$180 million initiative for offshore wind project development." Energy Alert, Hogan Lovells

06 February 2012 "Federal court rejects Vermont attempt to usurp NRC jurisdiction over continued operation of nuclear plant." Energy Alert, Hogan Lovells

01 February 2012 "FERC gives power plant owners an opportunity to weigh-in on critical procedure governing compliance with MATS rule." Energy Alert, Hogan Lovells

26 January 2012 "BLM seeks comment on competitive leasing for wind and solar development on federal lands." Energy Alert, Hogan Lovells

15 November 2011 "Department of Energy seeks industry input for 2012 electric transmission congestion study." Energy Alert, Hogan Lovells

12 July 2011 "FERC and DOE develop implementation proposal for National Action Plan on demand response." Energy Alert, Hogan Lovells

21 June 2011 "NRC proposed weapons rule on preemption authority and enhanced weapons." Energy Alert, Hogan Lovells

31 May 2011 "FERC requests industry comments on incentives for developing electric transmission." Energy Alert, Hogan Lovells

May 2010 "Climate Change Newsletter." Climate Change Newsletter, Hogan Lovells

15 October 2009 "DOE Issues First Solicitation Under Delegated Lender Program for Commercial-Scale Renewable Electricity Generation Projects." Energy Update, Hogan & Hartson LLP

08 October 2009 "Senate Climate Bill: What's in it for Natural Gas?" Energy Update, Hogan & Hartson LLP

31 July 2009 "DOE Issues New Loan Guarantee Solicitations For Innovative Energy Projects And New Transmission." Focus On Climate and Clean Energy, Hogan & Hartson LLP

24 March 2009 "Banking on the Department of Energy." Energy Update, Hogan & Hartson LLP

20 March 2009 "Department of Energy to Provide an Additional $3.1 Billion in Stimulus Funding to the States Under Its Existing State Energy Program." Focus On: Climate & Clean Energy, Hogan & Hartson LLP

20 March 2009 "Department of Energy to Provide an Additional $3.1 Billion in Stimulus Funding to the States Under Its Existing State Energy Program." Government Contracts Update, Hogan & Hartson LLP

06 March 2009 "Stimulus Legislation Update: Issue 4 - New Online Resources for Tracking Stimulus Funds." Stimulus Legislation Update, Hogan & Hartson LLP

18 February 2009 "Stimulus Legislation Update: Issue 3." Stimulus Legislation Update, Hogan & Hartson LLP

11 February 2009 "Stimulus Legislation Update: Issue 2." Stimulus Legislation Update, Hogan & Hartson LLP

10 February 2009 "Stimulus Legislation Update: Issue 1." Stimulus Legislation Update, Hogan & Hartson LLP

21 October 2008 "The United States and India Sign Agreement Permitting Civil Nuclear Trade With India." Hogan & Hartson Update, Hogan & Hartson LLP

07 October 2008 "Emerging Practice in Climate Change Disclosure by Public Companies." SEC Update, Hogan & Hartson LLP

01 October 2008 "Climate Change Disclosure: Emerging Practices." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

05 February 2008 "FTC Reviewing Green Guides." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

10 December 2007 "Voluntary Carbon Standard 2007." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

26 November 2007 "Energy Review, Volume 1, No. 6." Energy Update, Hogan & Hartson LLP

18 October 2007 "Regulated Carbon Markets in the United States." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

16 July 2007 "Overview of International and Domestic Climate Change Programs and Initiatives." Focus On Climate and Clean Energy, Hogan & Hartson LLP

09 May 2007 "Energy Review, Volume 1 No. 3." Energy Update, Hogan & Hartson LLP

06 April 2007 "Supreme Court Decides Global Warming Case." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

01 March 2007 "Energy Review, Volume 1, No. 2." Energy Update, Hogan & Hartson LLP

01 January 2007 "Energy Review, Volume 1, No. 1." Energy Update, Hogan & Hartson LLP

21 December 2006 "Aviation Update." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

12 December 2006 "Congress Authorizes Civil Nuclear Cooperation With India; U.S. Export Controls to be Eased." Hogan & Hartson Update, Hogan & Hartson LLP

11 December 2006 "Aviation and Greenhouse Gas Regulation." Focus On: Climate and Clean Energy, Hogan & Hartson LLP

16 August 2006 "Federal Loan Guarantees for Projects That Employ Innovative Technologies in Support of the Advanced Energy Initiative." Energy Update, Hogan & Hartson LLP

24 March 2006 "Regional Greenhouse Gas Initiative's Cap-and-Trade Program Presents Opportunities for Natural Gas Companies." Energy Update, Hogan & Hartson LLP

15 June 2005 "Nuclear Decommissioning: Managing the UK Nuclear Legacy." UK Briefing Paper, Hogan & Hartson LLP

16 February 2005 "Kyoto Protocol Enters Into Force February 16, 2005." Environment and Energy - Climate Change Update, Hogan & Hartson LLP

10 December 2002 "EU Council Reaches Agreement on European Greenhouse Gas Emissions Trading Schemes." EU Bulletin, Hogan & Hartson LLP

01 October 2001 "Carbon Trading in the European Community." Focus On, Hogan & Hartson LLP

Published Works
19 June 2014 "U.S. Nuclear Power Prospects." www.lexology.com, Association of Corporate Counsel

05 May 2014 "The Future of Nuclear Power." www.sciencedirect.com, The Electricity Journal

09 February 2012 "This Land Is Your Land: BLM Seeking Input On Solar Project Development." Solar Industry Magazine, Zackin Publications

November 2010 "Small and Modular Reactors: Putting America at the Nuclear Forefront (Again!)." Spark, Public Utilities Fortnightly Magazine

25 October 2010 "Small Nuclear May Be the Wave of the Future." National Law Journal, American Lawyer Media

26 October 2009 "ARPA-E Deserves Support." Environmental Leader

17 March 2009 "Banking on the Department of Energy." Legal Times, Incisive Media

September 2008 "Progress on the Path to the 'Full Portfolio': Utilities Prepare for Climate Change Regulation." Carbon & Climate Law Review

01 February 2008 "Federal Loan Guarantees." Electric Light & Power, PennWell Corporation

07 November 2007 "US Loan Guarantee Programme Opens the Door to New CO2-Reducing Technologies." Point Carbon

11 September 2006 "Liability for Nuclear Incidents: Should the UK Now Follow the U.S. Approach?" Journal of Environmental Law

12 June 2006 "States Get Together on Greenhouse Gases." Legal Times, American Lawyer Media

01 February 2006 "Voluntary Plans Will Not Cut Greenhouse Gas Emissions in the Electricity Sector." Sustainable Development Law & Policy

01 February 2006 "Global Energy Issue 1: North America and Europe." Mergermarket, Remark

01 November 2005 "New Era for U.S. Nuclear." Project Finance Legal Advisers Review 2005/2006

01 September 2004 "The Hard Realities of Energy Policy in an Election Year." Electric Light & Power

01 July 2003 "Standard Market Design: What Went Wrong? What Next?" The Electricity Journal

10 June 2002 "Kyoto Wasn't Last Gasp." Legal Times

PRACTICES
Energy
Climate Change
Infrastructure, Energy, Resources and Projects
Government Contracts
Government Regulatory
Environmental Litigation
INDUSTRY SECTORS
Energy and Natural Resources Group
Infrastructure
Renewable Energy
Energy Regulatory
Power
AREAS OF FOCUS
  • Electricity
  • Nuclear
  • Renewable Energy and Alternative Energy Technologies
  • Climate Change
  • Department of Energy Contracts/Grants

     

EDUCATION
J.D., Yale Law School, 1976 B.A., summa cum laude, Fordham University, 1973
MEMBERSHIPS
  • Board of Directors, Energy Bar Association 
  • Member, Energy and Environment Section, District of Columbia Bar Association
  • Member, Department of Energy Contractor Attorneys Association
AWARDS / RANKINGS
  • Chambers Global, Energy: Electricity (Regulatory & Litigation), 2007-2011; Energy: Nuclear (Regulatory & Litigation), 2011-2013
  • Chambers USA, Energy: Electricity, 2005-2008; Energy: Nuclear (Regulatory & Litigation) - Nationwide, 2009-2014; Climate Change, 2010-2014 
  • ABA Section on Environment, Energy and Resources, Distinguished Environmental Advocate, 2010-2011
  • Washington, D.C. Super Lawyers, Energy and Natural Resources, 2007, 2013 
BAR ADMISSIONS / QUALIFICATIONS District of Columbia
COURT ADMISSIONS U.S. Supreme Court U.S. Court of Appeals, District of Columbia Circuit U.S. Court of Appeals, Ninth Circuit U.S. District Court, Federal District of Colorado