Susan Scott

Susan Scott was a Senior Regulatory Attorney at Enron Transportation Services (ET&S), specializing in natural gas pipeline regulation and compliance with the Federal Energy Regulatory Commission (FERC). She served as lead regulatory counsel for Transwestern Pipeline Company, an Enron subsidiary, handling tariff filings, rate cases, and capacity allocation matters. Her work placed her at the intersection of Enron’s pipeline assets and the complex regulatory frameworks governing interstate natural gas transportation, and she became deeply involved in California energy market proceedings during the 2000-2001 crisis.

Scott’s email archive in the Enron corpus contains 15,200 messages spanning her active period through 2002, with correspondence from 554 unique senders. Her peak activity occurred during November and December 2000, coinciding with the height of the California energy crisis, when her monthly email volume reached 1,891 and 1,566 messages respectively.

Career at Enron

Position and Reporting Structure

Scott worked within the legal department of Enron Transportation Services, the division responsible for managing Enron’s interstate pipeline assets including Transwestern Pipeline Company, Northern Natural Gas, and Florida Gas Transmission. Based on correspondence patterns and organizational context, she likely reported to Richard Sanders, Executive Vice President and General Counsel. Her role was that of a working regulatory attorney rather than management, providing direct legal counsel to commercial operations teams while maintaining relationships with FERC staff, outside counsel, and industry counterparties.

Specialized Expertise

Volume-adjusted term analysis of Scott’s correspondence reveals the domains she distinctively owned within Enron’s operations. Her signature terms include interstate pipeline matters, SoCalGas (Southern California Gas Company), Sempra Energy, Dynegy, and GMSSR (her primary outside counsel firm). She ranked among the corpus leaders for terms related to testimony, exhibits, tariff compliance, and settlement negotiations.

Her primary collaboration was with Jeffery Fawcett, a commercial operations colleague with whom she exchanged 198 emails. This relationship exemplified the integration of legal and commercial functions characteristic of Enron’s pipeline operations, with Scott providing regulatory guidance while Fawcett handled customer relationships and business development.

Transwestern Pipeline Regulatory Work

Scott served as lead regulatory counsel for Transwestern Pipeline Company, which transported natural gas from the San Juan Basin in New Mexico and Arizona to California markets. Her responsibilities included FERC tariff interpretation and compliance, capacity allocation procedures, rate case preparation, and coordination with commercial teams on regulatory strategy.

Options Program Development

In 2000, Scott led the regulatory work on a major initiative to implement capacity options on Transwestern Pipeline. This innovative program would allow shippers to purchase options on future pipeline capacity, providing flexibility for customers while generating revenue for the pipeline. Her emails document the development process from initial concept through FERC staff presentations.

A September 2000 email titled “Outline of TW Options Program” laid out the regulatory framework, and by August 31, 2000, Transwestern had conducted a workshop with shippers to explain the new offering. The program required careful tariff language drafting and coordination with FERC staff to ensure compliance with existing regulations while introducing new commercial mechanisms.

Day-to-Day Regulatory Counsel

Beyond major initiatives, Scott provided ongoing regulatory advice to Transwestern’s operations. Her emails capture the granular nature of pipeline regulation: questions about tariff interpretation, customer index requirements, pooling agreement interpretations, and capacity release procedures. When commercial teams had regulatory questions, they turned to Scott for analysis and guidance.

One email exemplifies her analytical style: “I’ve looked at the pooling agreement and I agree with you – I don’t believe taking the compressor down is at all limited under the agreement.” This blend of legal precision and practical business advice characterized her value to the organization.

California Energy Crisis Response

The California energy crisis of 2000-2001 drew Scott into sustained regulatory engagement on gas market issues affecting the state. Her email volume tells the story: from modest pre-crisis levels, her activity surged to 1,891 emails in November 2000 and 1,566 in December.

CPUC Proceedings

Scott monitored and participated in California Public Utilities Commission proceedings related to natural gas procurement and pricing. Her work focused on the intersection of interstate pipeline regulation and California’s gas market, analyzing how FERC-regulated transportation services affected gas supply to the state’s utilities and power generators.

She coordinated regularly with Jeff Dasovich, Enron’s Director of Regulatory Affairs who served as the company’s primary California crisis manager. While Dasovich handled the political and public affairs dimensions of the crisis from Enron’s San Francisco office, Scott provided the pipeline regulatory expertise necessary to understand how gas transportation constraints affected California’s energy situation.

SoCalGas and Sempra Relationships

Scott maintained extensive correspondence with contacts at Sempra Energy, the parent company of Southern California Gas Company (SoCalGas). Brian Cherry, Gary Sullivan, and Zeb Angeles at Sempra were regular correspondents, with Cherry alone accounting for 156 emails. These relationships reflected both the adversarial nature of regulatory proceedings and the collaborative requirements of operating interconnected gas systems.

Her emails document ongoing attention to SoCalGas regulatory matters, proposed decisions affecting Enron’s California operations, and the complex interactions between FERC-regulated interstate pipelines and California-regulated local distribution companies.

FERC Regulatory Practice

Beyond Transwestern-specific matters, Scott conducted broad FERC regulatory work across Enron’s pipeline portfolio. Her expertise extended to interstate pipeline tariff compliance, certificate proceedings, affiliate transaction rules, market-based rate authority, and capacity release regulations.

Legal Research and Analysis

Scott’s emails demonstrate a rigorous approach to regulatory research. She cited FERC precedents in providing advice, such as “Texas Eastern Transmission Corporation, 74 FERC P 61,074 (1996),” and analyzed orders from other pipelines including El Paso to understand regulatory trends affecting Enron’s operations.

Her work products included legal research memos, analysis of regulatory developments, advice on negotiated rate structures, and interpretation of complex tariff provisions. Subject lines like “PNM filing: shipper must have title” and “tariff question” capture the ongoing nature of regulatory compliance support.

Red Cedar Jurisdictional Issue

Scott worked on a complex regulatory matter involving the Red Cedar gathering system and questions of FERC jurisdiction. The issue centered on whether certain facilities qualified as gathering (and therefore exempt from Natural Gas Act regulation under Section 1) or transmission (subject to FERC jurisdiction). Her correspondence with FERC staff member Mr. Hertzberg and coordination with colleagues Frank Kelly and Frazier King documented an ultimately unsuccessful attempt to obtain an exemption determination favorable to Enron’s position.

Litigation and Testimony

Scott regularly participated in formal regulatory proceedings as a witness and legal strategist. Her signature terms include “testimony” and “exhibits,” indicating frequent involvement in rate cases, certificate proceedings, and state regulatory hearings before bodies including the CPUC and New Mexico regulators.

Her work encompassed preparation of written testimony, development of exhibits for evidentiary hearings, settlement negotiations, and coordination with expert witnesses. The subject line “Gallup” in her archive refers to New Mexico regulatory matters where Enron’s pipeline interests required representation before state authorities.

External Relationships

Outside Counsel

Scott maintained heavy use of outside counsel at GMSSR (Glen, Morrison, Day & Scognamiglio LLP), a California-based law firm specializing in energy regulatory law. Her correspondence with [email protected] totaled 120 emails. Complex California regulatory work required local bar admission and specialized CPUC practice expertise.

This pattern suggests that for certain matters, Enron’s cost-benefit analysis favored retaining California regulatory specialists rather than handling all proceedings with in-house counsel.

Industry Relationships

Scott’s correspondence patterns reveal professional relationships with counterparts across the energy industry. She maintained regular contact with representatives from Calpine, Dynegy, and various shippers using Transwestern’s pipeline system. Subject lines referencing “Conference call with Phil Richardson and Sarah Tomalty of Dynegy” illustrate the collaborative interactions required in managing shared infrastructure and regulatory proceedings where multiple parties held stakes.

Regulatory Staff Contacts

Her emails document direct interactions with FERC staff for informal advice, pre-filing consultations, and procedural guidance. This hands-on regulatory practice distinguished Scott as an attorney who maintained active relationships with regulators rather than conducting purely transactional compliance work.

Key Correspondents

Scott’s correspondence patterns reflect her role as a working regulatory attorney integrated with commercial operations and external stakeholders.

The subscription to Wordsmith.org’s daily vocabulary service reflects a commitment to professional development, while the mix of internal colleagues, external counsel, industry contacts, and regulatory counterparts illustrates the multifaceted nature of her practice.

Email Activity

Scott’s email volume tracked the intensity of regulatory activity affecting Enron’s pipeline operations, with the California crisis driving peak correspondence.

The November 2000 peak represented nearly 100 emails per working day.

Working Style

Scott’s emails reveal characteristics of a highly competent regulatory lawyer with deep technical expertise in pipeline regulation. Colleagues turned to her for quick turnaround on urgent regulatory questions, and her responses demonstrate pragmatic problem-solving that integrated legal analysis with commercial realities.

Personal emails interspersed with professional correspondence show a Houston resident active in her community, with interests including the arts, symphony, and travel. Subject lines like “Heights question” reference Houston’s Heights neighborhood, while “NEA Funding Petition” indicates arts advocacy involvement. Regular Continental Airlines travel updates suggest frequent trips between Houston and regulatory proceedings in Washington and California.

Legal Status

Susan Scott does not appear in Department of Justice materials as a target of investigation related to the Enron collapse. Her role as a mid-level regulatory attorney working on pipeline compliance matters placed her outside the financial manipulation and accounting fraud that became the focus of criminal prosecutions. She represents the category of Enron employees who performed substantive professional work in good faith while remaining unconnected to the executive misconduct that destroyed the company.

See Also

• Jeff Dasovich - Director of Regulatory Affairs, California crisis coordination
• Steven Kean - VP Government Affairs, regulatory policy leadership
• California Energy Crisis - The regulatory crisis that drove Scott’s peak activity
• Enron Transportation Services - The division where Scott worked

References

This article is based on Susan Scott’s email archive in the Enron corpus, containing 15,200 messages from 554 unique senders. Primary source queries were executed against the Enron email database. The research file documents TF-IDF signature term analysis, correspondent network mapping, and email volume patterns.