Legislation and Rulemaking

Private Practice (1999-Present)

Development of comments on CEQ proposed revision of NEPA rules.
Development of comments on EPA proposed CERCLA § 108(b) rules.
Development of comments on EPA proposed regional haze SIP disapproval and FIP.
Development of comments on EPA proposed rulemakings governing states’ development of regional haze SIPs.
Development of comments on EPA rulemaking proposing to make primary SO₂ NAAQS more stringent.
Development of comments on EPA subsequent five-year review of primary SO₂ NAAQS.
Development of comments on EPA rulemaking proposing to make primary lead NAAQS more stringent.
Development of comments on state air quality rules governing responsible officials.
Development of comments on proposed state aquifer protection rules governing facility closure, post-closure monitoring and financial assurance.
Development of comments on a county’s proposal to amend it floodplain ordinances to include provisions on the improvement of riparian habitats.
Development of comments on EPA guidance on environmental justice.
Development of state legislation governing public access to state agency records.
Development of state legislation governing the administrative appeal process.
Development of state rules of procedure for judicial review of administrative decisions.
Development of state legislation on delisting designated uses of waters of the U.S.
Development of state legislation requiring opportunity for public comment prior to governor’s NAAQS attainment status recommendations to EPA.

Development of rules governing remedy selection.
Development of rules governing state assurance funding of LUST corrective actions.
Development of rules governing licensing timeframes.
Development of rules of procedure for contested cases.