Andrew R. Stewart

Andrew R. Stewart Counsel, Environmental & Natural Resources

Drawing upon his experience as a senior manager at the U.S. Environmental Protection Agency (EPA) and nearly 20 years in environmental law, Andrew counsels clients on a broad range of compliance and enforcement matters. His work includes assisting clients in the oil and gas and agribusiness industries on federal and state permitting requirements, counseling on other critical environmental obligations, and defense of government enforcement and citizen suit actions. Andrew has also led regulatory and policy advocacy before EPA and counseled regarding environmental risks and obligations in major transactions. These matters have arisen under all major federal environmental laws, as well as state laws.

Prior to joining Vinson & Elkins, Andrew served as an Acting Division Director in the Office of Civil Enforcement at EPA. He managed complex enforcement actions and litigation affecting numerous industrial sectors, including energy, chemical manufacturing, agribusiness, mining, and telecommunications. Andrew has negotiated and resolved enforcement matters arising under all major federal environmental statutes, including the Clean Air Act; Clean Water Act; Resource Conservation and Recovery Act; Comprehensive Environmental Response, Compensation, and Liability Act; Safe Drinking Water Act; and the Federal Insecticide, Fungicide, and Rodenticide Act.


Andrew received numerous awards for his enforcement work at EPA. Before coming to EPA, Andrew worked in the environmental practice of another firm in Washington, D.C. He frequently speaks on environmental issues and regulatory developments affecting the energy sector and other regulated industries, key government initiatives, and environmental auditing and risk management.

Experience Highlights

Since joining Vinson & Elkins, Andrew has counseled industry clients on many aspects of environmental law, including:

  • Represent companies in defense of enforcement actions under multiple environmental statutes 
  • Provide counsel regarding applicability and requirements of Clean Air Act NSPS OOOOa rule
  • Advise client on obligations under federal and state laws regarding upstream produced water pits and options for closing pits
  • Provide counsel regarding Clean Air Act permitting obligations for development of liquefied natural gas facility
  • Advise client regarding potential applicability of proposed EPA regulations covering upstream and midstream facilities
  • Provide counsel regarding Clean Air Act SIP provisions and engagement with state and EPA
  • Assist in defense of enforcement action relating to midstream natural gas operations
  • Provide counsel regarding requirements under EPA fuels regulations
  • Advise clients on structuring environmental audits and submitting disclosures under state and federal voluntary reporting programs 
  • Assist in review of potential liabilities under environmental laws regarding siting of liquefied natural gas facility
  • Counsel client on federal permitting and National Environmental Policy Act requirements for pipeline project
  • Assist in defense of citizen suit alleging Clean Air Act violations at petroleum storage and handling facility
  • Assist in analysis of federal and state permitting obligations at upstream natural gas operations
  • Represent companies before EPA on policy proposals applicable to federal reporting obligations

During his tenure at EPA, Andrew led various complex enforcement matters relating to the energy sector, including:

  • Cases alleging violations of requirements established under the Clean Air Act, including State Implementation Plan provisions, Maximum Achievable Control Technology standards, New Source Review/Prevention of Significant Deterioration permitting requirements, and the Section 112(r) General Duty Clause
  • Issuance of Clean Air Action Section 114 information requests to assess emissions at upstream natural gas operations
  • Actions for unauthorized discharges under the Clean Water Act NPDES program at upstream natural gas facilities
  • Actions under the Spill Prevention, Control, and Countermeasure program for violations involving condensate tanks
  • Investigations under the Clean Water Act relating to Publicly Owned Treatment Works and Centralized Waste Treatment facilities accepting wastewater from shale gas operations
  • Issuance of emergency orders under the Safe Drinking Water Act and CERCLA at natural gas exploration and production sites
  • Investigations under the Safe Drinking Water Act regarding the use of diesel fuels in hydraulic fracturing fluids
  • Resolution of numerous disclosures under EPA’s Audit Policy for multimedia violations at upstream facilities and natural gas processing plants

While at EPA, Andrew led enforcement matters affecting many other sectors and programs, including:

  • Resolution of actions under the Clean Air Act New Source Review/Prevention of Significant Deterioration and Leak Detection and Repair programs at chemical manufacturing facilities
  • Resolution of actions involving the Clean Water Act NPDES permit requirements at mining, pharmaceutical, and polyvinyl chloride facilities
  • Litigation and appeal of a significant action under the Federal Insecticide, Fungicide, and Rodenticide Act Worker Protection Standard 
  • Resolution of cases under the Clean Air Act, Clean Water Act, and Emergency Planning and Community Right-to-Know Act at telecommunications facilities
  • Handling actions, and issuance of Clean Water Act Section 308 requests, related to Concentrated Animal Feeding Operations
  • Actions under the Clean Water Act NPDES industrial storm water and construction storm water programs, as well as the Clean Water Act Section 404 program
  • Negotiation of corporate-wide audits to assess compliance under all major environmental statutes
  • Negotiation of Supplemental Environmental Projects in enforcement cases

Contact Details


T +1.202.639.6720
F +1.202.315.3392
2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037-1701
Local time: 2:49 PM
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Andrew's Practices

  • University of Virginia School of Law, J.D., 1997 (Editorial Board Member, Virginia Environmental Law Journal)
  • Duke University, B.A. cum laude, Dean’s List with distinction, 1994
  • Admitted to practice: District of Columbia; Maryland; U.S. District Court for the District of Maryland
  • Special Litigation and Projects Division, U.S. Environmental Protection Agency,  Washington, D.C., Acting Director, 2013–2015
  • Litigation and Audit Policy Branch, Special Litigation and Projects Division, U.S. Environmental Protection Agency,  Washington, D.C., Chief, 2006–2013
  • Water Enforcement Division, U.S. Environmental Protection Agency, Washington, D.C., Attorney-Advisor, 2003–2006
  • Judicial clerk to the Honorable Alexander Harvey II, U.S. District Court for the District of Maryland, 1997–1998
  • Guest Lecturer for Legal Drafting Seminar, The George Washington University Law School, Washington, D.C., 2009–2012
  • Legal 500 U.S., "Next Generation Lawyer" in Environment: Regulatory, 2016 and 2017
  • Vice Chair: Environmental Enforcement and Crimes Committee, ABA Section of Environment, Energy, and Resources