• Mining, Oil and Gas and Industrial Permitting
  • Judicial Review of Administrative Decisions
  • Environmental Enforcement Proceedings
  • Mineral Development Agreements
  • Federal Indian Law Proceedings
  • Permitting Feasibility Studies
  • Public Land Use Proceedings
  • Due Diligence Reviews

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.

Arizona Department of Environmental Quality (1996-1999)

  • 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.
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