Sarah Dicharry

Sarah Dicharry counsels energy-industry clients regarding compliance with federal statutes and regulations, represents clients in administrative and judicial appeal proceedings, and represents clients in response to government-initiated enforcement actions. She advises exploration and production companies regarding their rights and obligations under the complicated legal framework governing federal oil and gas leases. With the recent focus on offshore wind energy development in the United States, Sarah also has developed extensive knowledge regarding the regulatory framework governing offshore wind leases.

Sarah regularly counsels federal lessees regarding the complicated federal leasing framework, including concerning issues arising under the Federal Oil and Gas Royalty Management Act, the Royalty Simplification and Fairness Act, the Outer Continental Shelf Lands Act, the Mineral Leasing Act, the Indian Mineral Leasing Act, the False Claims Act, and the Administrative Procedure Act (APA). Within the context of these various statutes and their implementing regulations, Sarah advises companies regarding the scope of their rights and obligations, limitations on agency authority, responding to agency-initiated audits, etc. Sarah also helps clients develop comments on proposed rulemakings that affect federal leases. In addition to providing regulatory advice, Sarah advises and represents clients in corporate transactions, including asset acquisitions and divestitures (e.g., acquisition of offshore leases, sale of offshore pipeline segments).

Sarah also regularly represents clients in response to a variety of governmental investigations and enforcement actions, including matters arising under the federal leasing statutes (e.g., civil penalty assessments), investigations initiated by the Department of Interior’s Office of Inspector General under the Inspector General Act, proposed debarments, and investigations initiated by the Department of Justice under the False Claims Act.