Representative experience
Prepared the collective comments of 11 national industrial trade associations on EPA’s most important proposed changes to its hazardous waste generator rules in 35 years.
In last two years, defended clients in precedent-setting enforcement actions in Regions 3, 5 and 6 resulting in RCRA counts being dropped and 60% penalty reductions.
Represented the leading U.S. marketer of recycled coal ash in EPA rulemaking, legislation and citizen suit, resulting in favorable EPA decision to regulate ash as nonhazardous waste.
Prepared an Amicus brief for two multinational chemical manufacturers challenging EPA’s “legitimacy” criteria in its recycling rules.
