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Patrick Traylor
Patrick Traylor
Partner — Environmental & Natural Resources
Partner — Environmental & Natural Resources

Patrick Traylor

Patrick Traylor
Washington

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037

Houston

Texas Tower
845 Texas Avenue
Suite 4700
Houston, Texas 77002

Patrick Traylor

Environmental Enforcement Defense

  • Represents multiple independent oil and gas producers in Clean Air Act enforcement matters brought by the EPA related to the companies’ upstream production assets

  • Represents a private equity portfolio company in a Clean Air Act enforcement matter at a petrochemical facility initiated by Harris County, Texas and the Texas Commission on Environmental Quality

  • Represents a major industrial manufacturer with respect to compliance with the EPA’s nonroad engine rules

  • Represents multiple entities under investigation by the EPA for potential violations of Clean Air Act tampering and defeat device prohibitions

  • Represents a major engine manufacturer with respect to compliance with Clean Air Act certification matters

  • Represents multiple companies in making significant environmental audit disclosures to EPA and state environmental agencies

  • Represented a West Virginia wind energy facility in a U.S. Fish & Wildlife Service (FWS) criminal enforcement case under the Migratory Bird Treaty Act

  • Represented a gas-fired power plant operator in Texas in an internal investigation under the CAA

  • Represented a chemical manufacturer in Texas in an internal investigation under the CAA

  • Represented a Wyoming wind facility in a U.S. FWS criminal investigation under the Bald & Golden Eagle Protection Act

  • Represented a Maryland wind facility in a citizen suit case under the ESA

  • Represented a surface coal mine operator in New Mexico in a citizen suit case under the National Environmental Policy Act

  • Represented an underground coal mine operator in New Mexico in a citizen suit case under RCRA

  • Represented a coal-fired power plant operator in North Dakota in an EPA and North Dakota enforcement case under the CAA

  • Represented importers of tropical hardwoods in citizen suit cases under the Convention for the Import of Threatened and Endangered Species

  • Represented numerous coal-fired power system operators across the country in EPA, state, and citizen suit enforcement cases under the CAA

  • Represented automobile and engine manufacturers in EPA enforcement cases under the CAA

  • Represented coal-fired power plant operators in judicial challenges to their CAA construction permits

  • Represented a pork processing company in Virginia in an EPA enforcement case under the CWA

  • Represented a hazardous waste disposal company in a CERCLA cost reimbursement action against EPA

  • Represents a major natural gas transmission pipeline company in obtaining a Clean Air Act permit for a compressor station that is the subject of intense opposition

  • Represents a major oil refining company in the Clean Air Act permitting of an offshore crude oil export terminal

  • Represents a private equity portfolio company in Clean Air Act permitting of a liquified natural gas regasification and power production project

  • Represented an energy company in a major expansion of its refining capacity in Texas by securing a PSD permit

  • Represented a chemical manufacturing company in obtaining a PSD permit that would allow the continued use of its on-site power island

  • Represented an oil company regarding its use of anthropogenic CO2 in enhanced oil recovery operations

  • Represented a fertilizer manufacturing company in obtaining a PSD permit that would allow for a major expansion of its manufacturing operations in the Midwest

  • Represented a major international mining company in the expansion of coal mines in the American Southwest, including evaluating climate change-related impacts of coal combustion

  • Represented an ammonia manufacturing company in obtaining a PSD permit that would allow for the construction of a major new facility on the Texas Gulf Coast

  • Represented a waste-to-energy facility in obtaining a PSD permit that would allow for the construction of a new unit in an eastern state

Credentials

  • The George Washington University Law School, LL.M, Environmental Law, 1996
  • South Texas College of Law, J.D. (Member, South Texas Law Review), 1994
  • Texas A&M University, B.A., History, 1991
  • Deputy Assistant Administrator, U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, 2017–2019
  • Chambers USA, Environment (District of Columbia), 2012–2013 and 2022
  • Selected to the Washington, DC Super Lawyers list, Super Lawyers® (Thomson Reuters), 2014–2015
  • Legal 500 U.S., Environment: Regulatory, 2020 and 2022; Environment: Litigation, 2022
  • District of Columbia
  • Texas
  • Supreme Court of the United States
  • U.S. Court of Appeals, D.C. Circuit
  • U.S. Court of Appeals, Tenth Circuit
  • U.S. District Court, District of Columbia
  • U.S. District Court, District of North Dakota
  • U.S. District Court, Southern District of Texas
  • “EPA’s National Compliance Initiatives: Understanding EPA’s Enforcement Priorities in 2020-2023,” American Bar Association National Enforcement Conference, November 12, 2019 (panelist)