Paul C. Sarahan

Experience

Paul is well-versed in handling civil and criminal enforcement, permitting, auditing, litigation, workplace safety, air quality, water rights, water quality, waste handling and disposal, and Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund) matters.  He represents clients before TCEQ and the U.S. Environmental Protection Agency (EPA), as well as before state environmental agencies in Louisiana, Mississippi, Florida, Georgia, and Wyoming. Paul also has handled matters before the Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Coast Guard, Federal Aviation Administration (FAA), and Federal Railroad Administration (FRA).

• Advises companies on environmental audits, air compliance issues, environmental regulatory interpretations (EPA, TCEQ, and Texas Parks and Wildlife Department), the negotiation and revision of master service agreements, nondisclosure agreements, transportation-related regulatory interpretation (PHMSA and Texas Railroad Commission), safety-related regulatory interpretations (Occupational Safety and Health Administration, or OSHA)
• Assisted on a series of environmental issues, including electronic manifesting for waste transportation and disposal, and defense of an enforcement action by the TCEQ in the wake of Hurricane Harvey
• Representing clients in contested air permitting hearings
• Serving as a subject matter witness on environmental compliance history issues in a wastewater permitting hearing
• Prepared comments on behalf of an industry group and testified before the EPA on the EPA's
• Represented clients in Superfund matters
• Represented a shipping company to address environmental issues with the U.S. Coast Guard and TCEQ in response to a maritime accident
• Successfully defended a concrete company against criminal charges alleging unauthorized discharges to water
• Represented a chemical company in handling a criminal investigation; succeeded in avoiding criminal charges and all civil and administrative enforcement actions were dropped
• Represented a petrochemical facility in emergency response activities related to multiagency investigations and enforcement actions
• Represented chemical facilities on FRA and FAA enforcement actions
• Represented clients with respect to Texas Public Information Act requests, requirements, and exceptions
• Assisted buyers, sellers, and lending institutions in evaluating environmental issues, assessing potential liabilities, and creating solutions that provide a path for transactions to proceed to closing
• Advised on the establishment of a system for the collection, management, transportation, and disposal of hazardous or state-regulated waste generated in association with the operation of a grocery or pharmacy
• Advised on the applicability of Tier II hazardous chemical inventory reporting requirements to a grocery facility
• Successfully represented a grocery store in a civil enforcement action by a local government alleging violations of storm water and waste disposal requirements
• Advised on EPA regulation of articles under the Toxic Substances Control Act (TSCA) and the applicability of the EPA's reporting requirements under TSCA
• Advised on the handing, collection, storage, transportation, and disposal of off-spec or damaged products that may be subject to state or federal regulation as hazardous waste

Awards & Recognition

• Ranked: Chambers USA, Environment – Texas, 2017, 2019-present
• Best Lawyers in America, Environmental Law, 2016, 2018-present
  Litigation–Environmental, 2016, 2018–present
• Texas Super Lawyers, Environmental Law, 2014–2019
• The Legal 500 USA, Energy: Regulatory, 2015

Admitted to Practice

• Texas
• U.S. Court of Appeals, Fifth Circuit
• U.S. District Court, Southern District of Texas

Education

• University of Houston Law Center, Houston, Texas- LL.M., Environmental, Energy, and Natural Resources Law
  - LL.M., Environmental, Energy, and Natural Resources Law
• The University of Texas School of Law, Austin, Texas
  - J.D., with honors
• The University of Texas at Austin, Austin, Texas
  - B.B.A., Finance