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& natural resourcesenvironment

Whether your products are grown, extracted, or manufactured, Crowell & Moring’s environmental and natural resource lawyers can help guide you through the complex framework of laws that affect their production and use. Our lawyers have built a national reputation in such areas as water and air quality, endangered species, public land use, site cleanup and reclamation, biotechnology, toxic substances and pesticides, health and safety, and consumer products regulation. We also remain on the cutting edge of emerging areas such as climate change and nanotechnology.

We counsel and litigate on behalf of national trade associations, multinational corporations, and smaller companies, in addition to state and local governments, foundations, and other organizations. Our clients are engaged in the mining, silviculture, agriculture, construction, and defense industries, and manufacture products as diverse as agricultural and industrial chemicals, heavy equipment, motor vehicles, engines, pharmaceuticals, food products, steel, electronics, and consumer goods.

We represent those clients before the courts, Congress, and agencies, including the Environmental Protection Agency (EPA), the Department of the Interior, the Department of Agriculture, and numerous other federal and state agencies. While much of our practice involves efforts to shape the development of the law, we counsel and aggressively defend our clients in a wide range of civil and criminal investigations and enforcement proceedings. Our strong record of success in litigation includes two recent victories before the U.S. Supreme Court. Yet, because we are equally at home in other forums, we consider the full range of possible administrative, judicial, and legislative solutions and select those that will be most expeditious, cost-effective, and lasting. Our problem solving is frequently aided by our close affiliation with C&M International and C&M Capitolink, preeminent consulting firms that provide international trade, public affairs, and government relations expertise.

commitment

• Air Quality

• Endangered Species and Wildlife Protection

• Environmental Management Systems and Compliance Auditing

• Environmental Impacts and Historic Preservation

• Federal Lands

• International

• Legislation

• Superfund and Hazardous Waste

• Toxic Substances and Pesticides

• Toxic Tort Litigation

• Water Quality

• Workplace Safety and Health

R E P R E S E N TAT I V E I N D U S T RY S P E C I A LT I E S

• Agriculture

• Forestry and Forest Products

• Home Building and Other Land Development

• Mining and Reclamation

• Motor Vehicles

We are proud of our commitment to client service and our

creative approach to problem solving. We invite you to learn

more about our many practice areas, as described below.

air quality

Air Quality

We represent clients on a broad spectrum of issues arising from federal and state regulation of air emissions, including matters related to the control of stationary and mobile sources, climate change, permitting, strategic counseling, and enforcement, such as:

• Counseling companies on a variety of Clean Air Act (CAA) issues, including new source review, prevention of significant deterioration, Title V permitting, and compliance with new source performance standards.

• Advising clients on potential climate change issues and liability, including defending companies involved in global warming tort litigation.

• Defending clients in CAA administrative and civil enforcement actions.

• Counseling industrial clients regarding EPA’s development and implementation of hazardous air pollutant standards, including maximum achievable control technology and area source standards, and representing clients in EPA rulemakings to review and revise national ambient air quality standards.

• Counseling livestock producers on the application of federal and state air pollution controls to animal feeding operations.

• Counseling a major engine manufacturer on emissions compliance requirements for its on-road and non-road engine and vehicle products.

• Counseling a major automobile manufacturer regarding litigation against California’s greenhouse gas regulations.

• Advising a major automobile manufacturer regarding corporate average fuel economy requirements administered by the National Highway Traffic Safety Administration, including prospects for additional changes to existing requirements.

endangered species

Endangered Species and Wildlife Protection

Our lawyers are at the forefront of shaping the law under the Endangered Species Act (ESA), the Migratory Bird Treaty Act, and other wildlife protection laws, as described below:

• Representing industry clients in the Supreme Court’s most recent ESA cases—Babbitt v. Sweet Home, 515 U.S. 687 (1995); Bennett v. Spear, 520 U.S. 154 (1997); and National Association of Home Builders v. Defenders of Wildlife, Nos. 06-340, 06-549 (2007).

• Litigating ESA rulemakings, policies, and related agency actions on behalf of trade associations in home building, land development, silviculture, and agriculture, and defending companies against citizen suits and government prosecution for alleged ESA violations.

• Serving as general counsel to the Endangered Species Coordinating Council, a coalition of national trade associations, companies, and labor organizations seeking legislative reform of the ESA.

• Representing clients in all aspects of the ESA, including listing and delisting endangered and threatened species, designating critical habitat, recovery planning and species reintroductions, habitat conservation planning, and negotiating incidental take permits.

environmental management systems and compliance auditing

Environmental Management Systems and Compliance Auditing

We have counseled and represented companies and trade associations on a broad range of environmental, health, and safety (EHS) auditing projects and management systems, including:

• Compliance assurance—conducting EHS audits to evaluate compliance with applicable legal requirements, industry standards, and management practices.

• Transactional auditing—conducting audits and site assessments as part of “due diligence” inquiries into the environmental liabilities of companies, and assisting in drafting related contractual documents.

• Management systems—evaluating, designing and implementing EHS management systems (including ISO 14001, alternative models, and SEC/Sarbanes-Oxley components) in connection with, or in avoidance of, federal and state enforcement proceedings and suspension/debarment actions.

• Training and strategic planning—developing and conducting training and awareness programs for EHS coordinators, plant personnel, and senior management, while developing risk analysis and management strategies with a focus on securing competitive advantage through cost-effective compliance and sustainable development policies.

Some representative projects have included:

• Appointment by the U.S. District Court in Alaska, on the joint motion of BP Amoco and the U.S. Justice Department, to monitor the design and implementation of a nationwide environmental management system at all of BP’s oil exploration, drilling, and production facilities.

• Assisting the American Chemistry Council in combining its Responsible Care® Program with the ISO 14001 environmental management standards to create a hybrid RC14001® program and an enhanced Responsible Care® management system.

Environmental Impacts and Historic Preservation

Our lawyers are experienced in guiding land developers, mining and timber companies, telecommunications providers, and other clients through the complex environmental planning and historic review requirements of the National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA). We also defend those planning efforts when they are challenged by citizen groups, neighboring landowners, and other entities in court. Representative projects have included:

• Successfully defending a gold mining company before the Interior Board of Land Appeals against a neighboring landowner’s challenge to the adequacy of its environmental impact statement and plan of operation for a gold mine expansion in Nevada.

• Counseling a major land developer in California regarding the applicability of NEPA to the relocation of military training routes above its property as part of settlement negotiations with the U.S. Navy.

• Counseling clients on the application of NEPA to projects on tribal lands.

• Counseling various clients as to the meaning of “undertaking” under the NHPA to determine whether that Act applies to land development activities on public and private lands.

• Counseling a major city in New Mexico regarding the applicability of the NHPA and the Clean Water Act (CWA) to bridge and highway construction projects.

• Negotiating historic preservation agreements under the NHPA for logging roads, telecommunications facilities, and other development projects on federal lands.

environmental impacts and historic preservation

Federal Lands

Because one-third of the land base in the United States is owned by the federal government, we assist a wide range of resource developers in obtaining access to those federal lands. We also frequently defend their interests in administrative appeals and litigation. Our efforts have included:

• Securing, negotiating, defending, and litigating access across federal lands to private inholdings under the Alaska National Interest Lands Conservation Act.

• Assisting a major gold mining company with the expansion of its mines on national forest and public lands, completing two federal land exchanges in the process, and then successfully defending those actions in administrative and judicial appeals.

• Negotiating the largest federal/private coal land exchange in history and then successfully defending it in Northern Plains Resource Council v. Lujan, 874 F.2d 661 (9th Cir. 1989).

• Assisting a nationwide wireless provider with locating, permitting, and installing wireless telecommunications facilities on federal lands, including in National Parks.

• Commenting on and litigating such major rulemakings as the Interior Department’s revision of its environmental regulations for hardrock mining on federal lands and the Forest Service’s roadless area protection regulations.

• Litigating with and against, and appearing before, the federal land management agencies to secure favorable resource planning policies and decisions under the Healthy Forests Restoration Act of 2003, the National Forest Management Act, the Federal Land Policy and Management Act, the Wilderness Act, and the Wild and Scenic Rivers Act.

federal lands

international

International

As the global economy expands, our practice has expanded with it to meet our clients’ needs. Augmented by our London and Brussels offices and supported by our international trade affiliate C&M International, our lawyers frequently assist clients with complex legal issues arising under international law, trade agreements, and voluntary management codes, including the following representative projects:

• Counseling a multinational industry group regarding the development of a new international “Cyanide Management Code” for gold production.

• Analyzing and pursuing North American Free Trade Agreement claims arising from government actions “tantamount to expropriation” for foreign-owned mineral resource companies.

• Providing environmental due diligence, antitrust, and related advice to midsize

and large companies engaged in international joint ventures and transactions.

legislation

Legislation

Our lawyers, including two who have served as counsel to the relevant U.S. Senate committees, have extensive experience working with Congress on environmental and natural resources legislation on behalf of our clients. Our projects have included:

• Representing an industry coalition supporting responsible reform of the ESA on the bill which passed the U.S. House of Representatives in the 109th Congress.

• Preparing and presenting testimony to the U.S. House Resources Committee opposing the adoption of vague and overly broad legislation to protect Native American sacred sites.

• Working with Congress to protect valuable gold mining claims threatened by federal wilderness legislation and later successfully defending a company’s mine approval against appeals by tribal and environmental interests.

• Representing mining companies in the congressional debate over reform of the General Mining Law.

• Drafting and securing enactment of legislation raising statutory limits on acreages of federal mineral leases that companies may hold nationally and in each state.

legislationsuperfund and hazardous waste

Superfund and Hazardous Waste

We have practiced under the Comprehensive Emergency Response, Compensation & Liability Act (CERCLA) since the law was enacted in 1980, representing clients in connection with all aspects of that law, including:

• Counseling potentially responsible parties at numerous National Priority List sites.

• Defending against cost recovery actions, unilateral administrative orders, judicial enforcement, and claims for natural resource damages, while successfully pursuing pioneering theories of government liability.

• Designing cost allocations in litigation, alternative dispute resolution, and negotiated settlements, such as in City of North Miami v. Berger, 820 F. Supp. 989 and 828 F. Supp. 401 (E.D. Va. 1993).

• Representing owners and developers on brownfields redevelopment projects in negotiations with EPA and state and local agencies.

We have also counseled and defended clients in a broad range of Resource Conservation and Recovery Act (RCRA) enforcement and compliance matters, including:

• Negotiating favorable settlement terms to resolve citizen suit claims of “imminent and substantial endangerment” for alleged lagoon leakage. Sierra Club v. Seaboard Farms, Inc., et al., No. CIV-00-997-C (W.D. Okla.) (consent decree lodged Dec. 20, 2002).

• Obtaining summary judgment dismissal of RCRA hazardous waste disposal and “imminent and substantial endangerment” claims. Friends of Santa Fe County v. Lac Minerals, 892 F. Supp. 1333 (D.N.M. 1995).

• Persuading a federal court to vacate a RCRA consent decree and refund a penalty with interest because of “extraordinary” misconduct by EPA. United States v. Envirite Corp., 143 F.R.D. 27 (D. Conn. 1991).

• Counseling on all aspects of regulation under RCRA and corresponding state laws, including permitting, recycling projects, delisting, and rulemaking.

Toxic Substances and Pesticides

We have a broad toxic substances and pesticides practice, representing trade associations and companies on product-related matters under the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Emergency Planning and Community Right-to-Know Act (EPCRA), and related statutes. Our projects have included:

• Counseling and representing companies in connection with product registration and re-registration procedures and chemical classification programs, including novel product categories such as minimum risk pesticides, treated articles, and biotechnology products.

• Counseling on labeling and testing requirements, import requirements, marketing claims, new product development, and the applicability of new regulations and evolving agency guidance.

• Representing pesticide registrants in the negotiation of data compensation settlements, including defending against a petition to deny registration filed by an original data submitter.

• Participating with the American Bar Association in drafting white papers and briefing EPA’s General Counsel regarding the application of existing toxic and pesticide chemical statutes to the emerging area of nanotechnology.

• Representing chemical interests before EPA’s Office of Pesticide Programs regarding the application of existing laws to nanoscale pesticides.

• Counseling a trade group regarding Food and Drug Administration testing requirements applicable to agricultural commodities imported into the United States, including use of U.S. Pesticide Analytical Manual guidelines to affect minimal risk level policies in countries outside the United States.

• Defending against enforcement actions brought by EPA and its regional offices.

• Successfully litigating against EPA’s efforts to expand the Toxic Release Inventory program. Barrick Goldstrike Mines Inc. v. Browner, 215 F.3d 45 (D.C. Cir. 2000).

toxic substances and pesticides

toxic tort litigation

Toxic Tort Litigation

Our environmental and toxic tort practice includes trial and appellate litigation of agency enforcement cases, citizen suits, and challenges to agency actions under all of the major environmental laws, with a focus on claims for monetary damages, injunctive relief, response cost recovery, medical monitoring, and other claims involving contaminated sites and releases of hazardous substances. Our projects have included:

• Representing a major heavy equipment manufacturer in defending multiple class action lawsuits alleging neurological damage from exposure to welding fumes.

• Representing a city in Florida in litigation against a company whose improper disposal of spent solvents contaminated the city’s drinking water supply, recovering past and future cleanup costs in a four-week jury trial.

• Representing a major defense contractor in five consolidated class actions arising out of alleged contamination from the Hanford Nuclear Reservation and resulting claims for personal injuries, property damage, natural resource damages, and other tort claims. In re Hanford Nuclear Reservation Litigation, 894 F. Supp. 1436 (E.D. Wash. 1995).

• Defending a large airplane manufacturer in a toxic tort suit based on alleged contamination of groundwater.

water quality

Water Quality

Our water quality practice encompasses administrative and judicial enforcement proceedings, citizen suits, legislative efforts, participation in EPA rulemakings, and judicial challenges to those rules. Representative projects have included:

• Formal and informal agency advocacy related to major EPA regulations and policies, such as impaired waters/TMDL regulations, general permit requirements for industrial storm water discharges, and National Pollutant Discharge Elimination System (NPDES) regulations regarding concentrated animal feeding operations (CAFOs) and pesticide application.

• Litigation against, and in defense of, EPA regulations such as the Phase II storm water regulations, NPDES rules regarding CAFOs and pesticide application, and general permitting for construction-related storm water discharges. See, e.g., Waterkeeper Alliance, Inc. v. EPA, 399 F.3d 486 (2d Cir. 2005) (ruling EPA cannot require non-dischargers to seek NPDES permit coverage); Texas Independent Producers and Royalty Owners Association, et al. v. EPA, 410 F.3d 964 (7th Cir. 2005) (rejecting environmental groups’ challenge to construction general permit).

• Litigating challenges to national effluent limitations guidelines, including those applicable to the livestock, steel, and mining industries.

• Defending against administrative and judicial enforcement actions and citizen suits alleging unpermitted discharges or permit violations. Successful results include defending a major municipal wastewater treatment facility operator in a CWA criminal enforcement action, resulting in a deferred prosecution agreement that preserved the company’s government contracting ability.

• Negotiating NPDES permits for operations in mining, livestock, hazardous waste, and other industries in permit proceedings, and defending those permits in subsequent appeals.

• Advising numerous clients on storm water permitting and wetlands issues, including both jurisdictional questions and issues concerning nationwide and individual “dredge and fill” permits under CWA section 404.

• Advocating favorable EPA and Army Corps of Engineers policies, and providing Supreme Court amicus briefing on the scope of CWA jurisdiction over “navigable waters” and the exemption from dredge and fill permitting for farming, silviculture, and ranching activities.

workplace safety and health

Workplace Safety and Health

For over three decades, we have represented clients regulated under the Mine Safety and Health Act (MSHA). Our clients in this specialized area include large and small mining companies, industry trade associations, synfuel plants, coal consumers, and company officials subject to personal liability. We have represented mining industry clients in counseling and litigation in every conceivable problem area, including:

• Mine disasters and subsequent investigations and congressional hearings, civil and criminal investigations and enforcement, miner compensation claims, mine and workplace inspections, petitions for modification, labor relations and discrimination proceedings, and Equal Access to Justice Act claims for attorney fees.

• MSHA jurisdictional issues and rulemakings.

• Safety and health audits and training.

We have also served non-mining industry clients under the Occupational Safety and Health Act, including representing clients before the Occupational Safety and Health Administration (OSHA) to develop and revise workplace safety standards and counseling clients on the applicability of the OSHA asbestos standard for construction and redevelopment projects.

Our experience in this area is highlighted by our representation of industry in two of the largest safety and health cases: Secretary of Labor v. Keystone Coal Mining Corp., 151 F.3d 1096 (D.C. Cir. 1998), vacating over 3,500 civil citations alleging tampering with coal dust compliance samples, and AFL-CIO v. OSHA, 956 F.2d 962 (11th Cir. 1992), vacating 428 OSHA permissible exposure limits.

Our extensive experience in all areas of environmental and natural resource

law allows our team to provide a broad array of legal services to increasingly

regulated industries, ranging from agricultural and forestry to construction and

mining. Some representative industry specialty areas are described below.

Agriculture

We represent the agricultural industry in local, regional, and national environmental litigation and rulemakings, providing regulatory compliance counseling in virtually all areas of environmental and natural resource law to growers and producers; pesticide, fertilizer, and other product manufacturers; and national trade associations. Our projects have included:

• Representing multiple national trade associations in connection with revisions to EPA’s NPDES regulations for CAFOs.

• Negotiating a novel, national-in-scope, industry-wide CWA enforcement agreement on behalf of the pork industry.

• Advising several national trade associations on issues associated with air emissions from livestock facilities, and negotiating with EPA a unique national CAA enforcement moratorium for a variety of animal feeding operations in exchange for performing an emissions monitoring study.

• Representing a group of national trade associations in challenging revisions to EPA’s impaired waters/TMDL regulations.

• Representing national trade associations on issues concerning the assertion of CWA jurisdiction over the use of pesticides.

• Representing a national agricultural chemical trade association in defense of ESA citizen suits that would enjoin the registration and use of pesticides.

• Defending individual livestock and dairy producers in EPA and state enforcement actions and in citizen suits brought under a variety of environmental laws.

representative industry

Forestry and Forest Products

We represent trade associations, companies, and other clients in a wide array of litigation and administrative and legislative matters relating to forestry and timber management on private, federal, and state lands, including:

• Securing a unanimous Supreme Court opinion establishing general lack of jurisdiction for environmental groups to bring programmatic challenges to Forest Service resource management plans in Ohio Forestry Association, Inc. v. Sierra Club, 523 U.S. 726 (1998).

• Defending companies targeted by citizen suits and government enforcement actions alleging violations of environmental laws and regulations relating to their timber management activities on private lands and their purchase and harvesting of timber on federal and state lands.

• Serving as national litigation counsel for the industry on natural resource, forest management, and timber supply matters.

• Pursuing judicial, administrative, and legislative solutions concerning: (1) the applicability of the ESA and other wildlife laws and policies to silvicultural activities on private and public lands; (2) point source permitting, nonpoint source programs, dredge and fill permitting, and other wetland and water quality protections under the CWA; and (3) pesticide registration and application under FIFRA.

Home Building and Other Land Development

Land development activities frequently trigger complex legal issues associated with endangered species protection, wetlands-area development, storm water control, historic preservation, and environmental planning. Our lawyers are expert in developing compliance strategies under the various federal and state counterpart statutes that apply to development activities on private and public lands, including NEPA, NHPA, ESA, and CWA, and defending those strategies against government enforcement actions and citizen suits when necessary. Our work has included:

• Defending a large national home builder in a nationwide enforcement action for alleged violations of EPA’s storm water program.

• Representing the National Association of Home Builders in litigation brought by environmentalists challenging EPA’s general permit for storm water discharges, and successfully moving for dismissal of those claims on standing grounds. Texas Independent Royalty Producers & Owners Association v. EPA, 410 F.3d 964 (7th Cir. 2005).

• Assisting the largest private landowner in California in its efforts to develop an entire city, including negotiating a habitat conservation plan and incidental take permit under the ESA.

• Providing ESA and NEPA compliance counseling for the developer of a ski resort in Colorado, including assessing litigation strategies to overcome challenges by local environmental organizations during project implementation.

specialties

Mining and Reclamation

Mineral and coal extraction and reclamation activities often pose unique legal issues and challenges, for which our lawyers are uniquely qualified. For example, we have assisted mineral resource companies in acquiring and exercising rights to federally owned minerals and conducting mineral exploration and development operations on public lands. We advise and defend companies on issues arising under public lands, natural resource, environmental, endangered species, and historic preservation laws. We have also counseled and represented the coal industry in litigation under the Surface Mining Control and Reclamation Act (SMCRA) since its enactment in 1977. Our diverse experience in these areas includes:

• Winning reversal of a Ninth Circuit decision before the U.S. Supreme Court, establishing that sand and gravel were not reserved to the federal government as “valuable minerals” in Nevada land patents. BedRoc Limited LLC v. United States, 541 U.S. 176 (2004).

• Securing dismissal on behalf of 18 major mining companies of a qui tam action seeking billions of dollars in damages based on allegations that “foreign controlled” companies were unlawfully mining gold, silver, and other minerals from public lands.

• Counseling on, and litigating, the major legal issues arising under SMCRA, such as state primacy, subsidence, valid existing rights, mountaintop mining, offsite support facilities, and hydrology. See Citizens Coal Council v. Norton, 330 F.3d 478 (D.C. Cir. 2003) (addressing subsidence issues in surface coal mining).

• Resolving problems associated with the Interior Department’s Applicant Violator System (AVS), including enjoining and overturning permit blocks, assisting in ownership and control determinations, and representing the National Mining Association in litigation that set aside the regulations implementing the AVS. See National Mining Association v. U.S. Department of the Interior, 105 F.3d 691 (D.C. Cir. 1997) and 177 F.3d 1 (D.C. Cir. 1999).

• Successfully challenging an Interior Department regulation imposing an unlawful interest rate on federal coal lease royalties in Amax v. Quarterman, 181 F.3d 1356 (D.C. Cir. 1999).

• Defending a large mining company against CWA and Superfund natural resource damages claims.

• Representing major coal and mineral companies in litigation and arbitration proceedings involving coal and mineral supply agreements, lease agreements, competing severed mineral interests, and similar mineral-related disputes, as well as providing contract drafting and negotiation advice in disputes that have not reached litigation.

representative industry

Motor Vehicles

Manufacturers of motor vehicles and their suppliers, including heavy-duty truck and engine builders, automobile manufacturers, automotive and truck component suppliers, and motorcycle manufacturers, face a variety of environmental and safety regulations applicable to their products. Our lawyers are uniquely qualified to address those issues from a product perspective, as well as on a statute-by-statute basis. For example, our lawyers have direct experience in the areas of federal and state emissions certification, vehicle safety issues under federal motor vehicle safety standards, and parts marking, parts origin, and corporate average fuel economy issues. Representative projects have included:

• Advising a heavy-duty engine manufacturer on strategy associated with obtaining federal certification for new technology engines meeting more stringent 2007 emission standards.

• Advising an equipment supplier regarding compliance with the American Automobile Labeling Act.

• Coordinating and responding to threatened and proposed legislation rolling back ultralow sulfur diesel fuel standards drafted in response to 2005 hurricane disasters, by providing alternative legislative language and meeting with appropriate congressional staff on behalf of a heavy-duty engine and truck manufacturer.

• Obtaining an exemption from the dual fleet provisions of the corporate average fuel economy requirements on behalf of a worldwide automobile manufacturing company.

• Developing a comprehensive strategy for vehicle classification for a major automobile manufacturer to maximize flexibility under fuel economy requirements.

• Obtaining favorable interpretation letters from the National Highway Traffic Safety Administration regarding application of federal motor vehicle safety standards to client products.

• Representing major automobile manufacturers in investigations into alleged safety related defects and noncompliance under the National Traffic and Motor Vehicles Safety Act.

• Advising and counseling automotive equipment suppliers regarding reporting requirements under the Transportation Recall Enhancement, Accountability and Documentation Act.

specialties

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For further information regarding Crowell & Moring’s Environment & Natural Resources practice, please visit our website at: www.crowell.com or call 202.624.2500.