Randy is an environmental attorney with extensive experience with petroleum-refining, semi-conductor, copper mining/smelting, electric utility, landfill and other industry sectors. Broad-based regulatory and litigation experience in the areas of air quality permitting and compliance, climate change, solid and hazardous waste regulation, water quality, underground storage tanks, and Superfund. Significant experience in negotiating consent decrees and resolving compliance issues with various EPA Regions. Representative Experience REGULATORY EXPERIENCE Permitting and compliance experience in federal PSD, Title V, New Source Review, asbestos NESHAP, and NSPS air quality programs. Representing national and international industries in air quality permitting, compliance strategy development, and environmental enforcement issues. Air quality permitting experience in over a dozen states, including Alabama, Arizona, California, Florida, Georgia, Illinois, Indiana, Mississippi, New Jersey, New Mexico, North Carolina, Texas, and Utah. Advising clients on regulatory and transactional risks associated with current and pending climate change legislation. Air quality experience with a broad range of industries, including utilities, petroleum refineries, mining companies, semi-conductor manufacturers, major airlines, chemical companies, textile companies, trade associations, fertilizer manufacturers, and a variety of other industries. Providing legal advice on release-reporting requirements under CERCLA/EPCRA. Preparing comments on dozens of federal, state, and local environmental rulemakings. AUDITING EXPERIENCE Working with national and international companies in developing and implementing effective environmental management systems. Conducting comprehensive, multi-media environmental audits for large, complex, industrial facilities in various states. Providing compliance determinations under federal, state, and local environmental programs, including RCRA, CERCLA, EPCRA, Clean Water Act, and Clean Air Act. Preparing environmental assessment protocols for dozens of industrial facilities. LITIGATION EXPERIENCE Serving as coordinating counsel for multi-industry, multi-state air quality appeals before the District of Columbia and Ninth Circuit Courts of Appeal. Representing companies in responding to EPA Section 114 Information Requests. Negotiating consent decrees for alleged violations of the Clean Air Act and CERCLA. Obtaining approval for supplemental environmental projects to offset penalties. Conducting employee interviews to determine potential liabilities for companies and their executives. Representing companies in responding to citizen suits under the Clean Air Act. TRANSACTIONAL EXPERIENCE Represented one of the nation's largest banks in the financing of a 55MW utility-scale solar facility (approximately $250MM in value) in New Mexico. The bank provided the construction financing and will provide the long-term financing. Lead environmental counsel for a major Southeastern utility on multiple power plant acquisitions and due diligence investigations in Georgia, Florida, North Carolina, Mississippi, Pennsylvania, and Maryland. Represented a major Australian bank in the environmental due diligence investigation of a large industrial borrower in the U.S. LOBBYING/OTHER EXPERIENCE Lobbying experience on Arizona, New Mexico, and federal air quality issues. Directing voluntary remediation projects. Negotiating NPL-listing deferrals for contaminated sites. Providing critical evaluation of potential liabilities identified through Phase I/Phase II environmental assessments. Articles and Presentations "Preparing for a Regulatory Inspection," Electric Perspectives, July/August 2011. "Regulation of Greenhouse Gases: Title V Operating Permits," Troutman Sanders LLP/Trinity Consultants, July, 20, 2010. "A Legal Perspective on Greenhouse Gas Regulation: Recent Court Decisions on Climate Change and the Implications for the Landfill Industry," 32nd Annual SWANA Landfill Gas Symposium, Thursday, March 12, 2009, Atlanta, GA. Recent Trends in CAA Citizen Suits: Managing Risk in the Serengeti, Natural Resources & Environment, Volume 20, Number 3, Winter 2006. "Enforcement Trends and Compliance Strategies." Southeast Air Quality Conference (March 2005). Speaking Whale: The Impact of Georgia's New Nonattainment Designations on the Georgia Business Community, Georgia Bar Journal, June 2004. "Trends in Clean Air Act Citizen Suits and Permit Appeals." Southeast Air Quality Conference (March 2004). "Air Permits, Regulations, and Requirements." National Business Institute (2003). "EPA's Regional Haze Rule: Coming Into View." Institute of Continuing Legal Education in Georgia; Environmental Law Summer Seminar (2002). "The Information Age: No Right to Remain Silent Under the Clean Air Act." Georgia and Southeast Environmental News (2001). "Environmental Considerations in Indian Country." Arizona Environmental Law Manual,1999, 2000. "Environmental Law: The Seven Deadly Sins Your Company Can't Afford to Commit." Arizona Journal, October, 1999. "The Promulgation and Appeal of EPA's Tribal Air Rule." CLE International, 1999. "Class I Redesignation-A Recipe for Sovereign Conflict." CLE International, 1998. Arizona State Bar, Environmental and Natural Resources Law Newsletter. Featured in The Arizona Business Gazette - Profiles in Success, 1998. Public Service Board Member, Dunwoody Nature Center Other Distinctions Recognized as one of America's Leading Lawyers for Environmental Law by Chambers USA (2010-2011) Recognized in The Best Lawyers in America in Environmental Law (2012) Selected by Law & Politics and Atlanta Magazine as a Georgia Super Lawyer in Environmental Law (2005-2011); Selected as a Georgia Rising Star in Environment/Land Use by Law & Politics and Atlanta Magazine (2005) Recipient of the University of Oklahoma's Regents' Alumni Award (2000) Work Experience 2001-present, Partner, Troutman Sanders 2000-2001, Of Counsel, Troutman Sanders 1995-2000, Gallagher & Kennedy Memberships · State Bar of Georgia · Arizona State Bar · Member, Georgia Coalition for Sound Environmental Policy · Member, Metro-Atlanta Chamber of Commerce · Member, Air and Waste Management Association · Former Member, Arizona Chamber of Commerce (Committee on Environment) · Member, Solid Waste Association of North America |