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About Ryan

Ryan Eletto focuses on environmental strategy, energy regulation, regulatory matters and public policy issues. He advises clients in litigation, investigation, enforcement and compliance matters involving administrative agencies, including the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC). Ryan also works on matters relating to state and federal energy and environmental statutes, such as the Toxic Substances Control Act, Clean Air Act, Clean Water Act and Natural Gas Act.

Prior to joining Bracewell, Ryan served as a law clerk to the Honorable Bruce E. Kasold of the U.S. Court of Appeals for Veterans Claims in Washington, D.C. During his time at the University of North Carolina School of Law, he received the Eugene Gressman and Daniel H. Pollitt Oral Advocacy Award and was a member of the Holderness Moot Court National Team.

Experience

Recent Notable Matters

Upper Bay Infrastructure Partners — Acquisition of Tidewater Transportation & Terminals, a multi-commodity transportation, terminal, and marine construction and repair company serving the Pacific Northwest, from Stonepeak Infrastructure Partners. Upper Bay Infrastructure Partners was the lead investor of a group consisting of Ullico, funds and accounts under management by BlackRock, Silverfern and certain other co-investors.  

Chemical import companies — compliance under the Toxic Substances Control Act (TSCA) and federal pesticide laws (FIFRA), and related regulatory compliance and policy analysis strategies

Affiliate of Brookfield Asset Management Inc — strategic investment with Landmark Infrastructure Partners LP in forming a joint venture to invest in core infrastructure assets

Venoco, Inc. and its affiliated debtors in possession — Chapter 11 petitions in the U.S. Bankruptcy Court for the District of Delaware to restructure their debt obligations and capital structure and its affiliates Denver Parent Corporation, TexCal Energy (LP) LLC, Whittier Pipeline Corporation, TexCal Energy (GP) LLC, Ellwood Pipeline, Inc., and TexCal Energy South Texas, L.P., which included advocacy at the confluence of bankruptcy and environmental law, drafting discovery documents and other court filings, preparing expert witnesses, and advising on state and federal regulatory issues associated with oil and gas decommissioning

Publications and Speeches

Co-author, “Practitioner Insights: Environmental Auditing in New Regulatory Era,” Bloomberg Environment & Energy Report, February 5, 2018.

What to Expect When You Don’t Know What to Expect: Working the EHS Regulatory Crystal Ball, Young Professionals in Energy Austin Chapter, May 5, 2017.

President Trump’s SCOTUS nominee, Judge Neil Gorsuch, suggests a weakening of the Chevron Doctrine with less deference to rulemaking efforts from EPA, DOI and other federal agencies, Oil & Gas Financial Journal, February 10, 2017.

Credentials

Education

University of North Carolina at Chapel Hill School of Law,
J.D.
2014
cum laude
University of Southern California,
B.A.
2010

Bar Admissions

District of Columbia
New York

Affiliations

New York State Bar Association
District of Columbia Bar Association
American Bar Association

News

Insights

Insights

DOJ’s Environmental Enforcement Priorities and Expectations – Refocusing on the Rule of Law

In recent months, the U.S. Department of Justice (“DOJ” or the “Department”) has issued a series of memoranda from the Department’s highest levels to its various component divisions, which includes the Environment and Natural Resources Division (“ENRD”). The ENRD is charged with...

U.S. Futures Exchanges Disciplinary Actions Alert: March 2018

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a...

U.S. Futures Exchanges Disciplinary Actions Alert: February 2018

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and...

U.S. Futures Exchanges Disciplinary Actions Alert: January 2018

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities...

U.S. Futures Exchanges Disciplinary Actions Alert: December 2017

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities...

Rescission of BLM’s Hydraulic Fracturing Rule: What Happens Now?

January 8, 2018

In one of the Trump Administration’s final acts of 2017, the U.S. Bureau of Land Management (BLM) formally announced on December 29, 2017, its rescission of the 2015 final rule regarding hydraulic fracturing on federal and tribal lands (2015 final rule). This...

U.S. Futures Exchanges Disciplinary Actions Report - November 2017

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and...

U.S. Futures Exchanges Disciplinary Actions Report - October 2017

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and...

CFTC Annual Enforcement Update

On November 22, 2017, the Commodity Futures Trading Commission (“CFTC”) released its annual enforcement report for fiscal year 2017. As in previous years, this year’s report highlights the agency’s continued commitment to enforcement and aggressive pursuit of those viewed as engaging in conduct that undermines the integrity of...

New Tactics, Same Result: Local Efforts to Regulate Hydraulic Fracturing Continue to Falter Despite New Approaches to Regulation

October 13, 2017

Despite numerous attempts in recent years by local governments to regulate oil and gas activities at the municipal level, recent developments in Pennsylvania, Ohio and Colorado signal a continued trend favoring states’ authority to regulate these issues as matters...

U.S. Futures Exchanges Disciplinary Actions Report - September 2017

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and...

U.S. Futures Exchanges Disciplinary Actions Report - August 2017

The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular...

U.S. Futures Exchanges Disciplinary Actions Report - July 2017

NYMEX NYMEX 15-0305-BC Position Limits Violation of Rule 562 – Position Limit Violations On August 9, 2016, a Probable Cause Committee (“PCC”) panel charged a non-member entity with violating NYMEX Rule 562, based on allegations that on November 23, 2015...

CFTC Fines and Imposes Permanent Ban on Trader Accused of Spoofing

On July 26, 2017, the U.S. Commodity Futures Trading Commission (“CFTC”) issued an order approving a settlement resolving allegations that Simon Posen of New York violated the CFTC’s prohibition on spoofing by entering bids or offers with “the intent to cancel the bid or offer before execution.” [1] Posen’s transactions occurred in gold, silver, and copper futures contracts (on the Commodity Exchange, Inc.) and crude oil futures contracts (on the New York Mercantile Exchange). Mr. Posen was not, at the time, employed by any corporate entity. According to the order, Mr. Posen engaged in...

U.S. Futures Exchanges Disciplinary Actions Report - June 2017

NYMEX NYMEX 16-0498-BC Position Limit Violation of Rule 562 – Position Limit Violations Pursuant to a settlement offer, a Business Conduct Committee panel (“BCC Panel”) found that on July 27, 2016, a non-member entity held a futures equivalent long position of 1,159.25 contracts in August 2016 Henry Hub Natural Gas Look-Alike Last Day Financial Futures, which was 159.25 contracts, or 15.925%, beyond the standard expiration month limit. As a result, the non-member entity may have violated Rule 562. $50,000 fine. NYMEX 16-0600-BC Misc. Violation of Rule 432 – General Offenses, Rule 576 –...

U.S. Futures Exchanges Disciplinary Actions Report - May 2017

NYMEX NYMEX 16-0372-BC Misc. Violation of Rule 432.Q, 432.W – General Offenses Pursuant to a settlement offer, a panel found that from July 2015 through March 2016, a non-member trader was concomitantly operating market-making and market-taking automated trading systems during the pre-opening period that entered and cancelled a number of E-mini Crude Oil and Natural Gas futures contracts orders. The market-taking strategy should not have operated in the pre-opening period and the orders it generated were not intended to be entered. Due to the non-member trader’s inability to properly...

Unusual Dynamics Of Upstream Distress - Environmental Law Seminar, Spring 2017

May 4, 2017

A high-level presentation on financial distress affecting upstream oil and gas companies. The presentation discusses factors that precipitated this distress (such as low commodity prices), the effects of such distress (such as accelerated decommissioning obligations), and highlights key challenges and takeaways of note.

For Those Keeping Tally, Another Win for Defendants’ Rights: Exploring De Novo Review and Burdens of Proof

On March 30, 2017, the U.S. District Court for the Eastern District of California issued an order denying, without prejudice, the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Motion to Affirm Civil Penalties against Barclays Bank PLC and four individuals (“Defendants”). [1] As an initial matter, the court agreed with every other federal court that has opined on the issue of whether defendants are entitled to conduct discovery under the Federal Rules of Civil Procedure. [2] Notably, though, the court went further than any other court in rejecting arguments raised by FERC...

President Trump’s SCOTUS Nominee, Judge Neil Gorsuch, Suggests a Weakening of the Chevron Doctrine With Less Deference to Rulemaking Efforts from EPA, DOI and Other Federal Agencies

January 31, 2017

On January 31, President Donald Trump selected Judge Neil Gorsuch as his nomination for the United States Supreme Court seat left open by the death of Justice Antonin Scalia nearly a year ago. From an environmental law perspective, it is most notable that the decisions penned by Judge Gorsuch have called for the reassessment and potential revocation of Chevron deference to agency interpretation of its own statutes, a doctrine Justice Scalia championed in his early days before exhibiting a degree of flexibility about it later in his tenure on the bench. Because most environmental regulations...

Noteworthy

Noteworthy

Thomson Reuters
Washington, DC Super Lawyers
Rising Star, 2018
UNC School of Law
Death Penalty and the Supreme Court, Top Grade, Spring, 2014

Events