Paul C. Sarahan

Paul Sarahan focuses his practice on environmental, safety, and transportation issues. He has more than 25 years of experience in policy, regulation, and commercial use of the environment and has represented clients in the energy, chemical, manufacturing, transportation, and retail industry sectors before federal, state, and local agencies. Key experience includes providing regulatory counseling, advising clients on environmental auditing, and representing clients in cost recovery and remediation cases.

Phone: (512) 615-1215

Professional Background

Publications & Presentations

Professional & Community Activities

Professional Background



  • Assisting a midstream oil and gas company on environmental audits, air compliance issues, environmental regulatory interpretations (U.S. Environmental Protection Agency, or EPA; Texas Commission on Environmental Quality or TCEQ; and Texas Parks and Wildlife Department), the negotiation and revision of master service agreements, nondisclosure agreements, transportation-related regulatory interpretation (Pipeline and Hazardous Materials Safety Administration, or PHMSA; and Texas Railroad Commission), safety-related regulatory interpretations (Occupational Safety and Health Administration, or OSHA)
  • Representing a client in defending the Central Texas quarry industry's grandfather status with respect to permitting requirements under the TCEQ's Edwards Aquifer rules
  • Assisted a grocery company 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
  • Assisting a hotel company in a series of environmental audits
  • Representing a concrete manufacturing facility in a contested air permitting hearing
  • 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 proposed rule addressing Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards
  • Represented clients in civil and criminal environmental enforcement actions brought by local governments
  • Represented clients in administrative enforcement actions brought by the TCEQ and the EPA
  • Assisted clients in developing and implementing environmental audit programs addressing air, water, waste, and Emergency Planning and Community Right-to-Know Act (EPCRA) issues
  • 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
  • Advised a trade association regarding TCEQ's interpretation of water rights rules during drought conditions
  • Successfully represented a municipal utility district in defending against an appeal of its water rates
  • Advised a waste disposal company regarding the applicability of TCEQ's permitting requirements to its wastewater operations
  • Successfully defended a concrete company against criminal charges alleging unauthorized discharges to water
  • Assisted an estate on remediation of its former gas station facility through TCEQ's state lead program
  • Represented clients in Superfund matters, including formation of a potentially responsible parties (PRP) group and the expansion of that group to minimize the clients' total cost of remediation
  • Successfully obtained the dismissal of a client from Superfund litigation
  • 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
  • Advised various oil and gas operations on Texas Commission on Environmental Quality (TCEQ) enforcement matters, including investigations related to operations in the Barnett Shale, air permitting matters, emissions inventory issues, greenhouse gas reporting requirements and U.S. Department of Transportation (DOT) registration requirements
  • Advised various pipeline operations on Pipeline and Hazardous Materials Safety Administration (PHMSA) enforcement matters
  • Advised a midstream oil and gas company on Quad Z, Quad J, Quad O and Quad Oa issues, and on environmental audit issues
  • Advised refinery, chemical, and midstream oil and gas operations regarding various air issues, including Title V compliance, emission event reporting requirements, permitting and greenhouse gas reporting requirements
  • Represented a power plant in seeking a reversal of a negative use determination on an application for an environmental tax exemption
  • Advised a midstream oil and gas company on master service agreements and other contracting issues

Other Litigation Matters:

  • Represented waste facilities in administrative permitting hearings, and in related state district court litigation
  • Represented a chemical facility in handling an emergency response incident, including a site investigation by federal, state, and local governmental agencies, and subsequent personal injury lawsuits and an environmental enforcement action
  • Represented chemical facilities on Federal Railroad Administration (FRA) and Federal Aviation Administration (FAA) enforcement actions
  • Advised clients on Occupational Safety and Health Administration (OSHA) requirements
  • Represented clients with respect to Texas Public Information Act requests, requirements, and exceptions
  • Assisted in the representation of an industry consumers group contesting proposed electricity rate increases in Mississippi, Texas, and New Mexico

Transactional Experience:

  • 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
  • Assisted a transportation company in an environmental due diligence review of more than 200 of its facilities as part of its negotiation of a renewal of a credit agreement
  • Advised a lending institution on environmental issues, including applicable remediation requirements; and the likely expenses and time associated with that remediation, as related to property that was the subject of the proposed transaction

Food and Drug:

  • Advised on the negotiation of a master services agreement addressing the handling, transport, delivery, and pump-out of refrigeration grade anhydrous ammonia supplies, including insurance, indemnity, compliance, and representations and warranties
  • 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 negotiation of a master services agreement addressing the transportation, treatment, storage, incineration, recycling, management, and/or disposal of water products 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
  • Developed a compliance plan to ensure that a grocery facility no longer triggered Tier II hazardous chemical inventory reporting requirements
  • 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 the U.S. Environmental Protection Agency's (EPA) regulation of articles under the Toxic Substances Control Act (TSCA) and the applicability of the EPA's reporting requirements under TSCA
  • Advised on a grocery store's compliance with petroleum storage tank requirements related to its operation of gas stations at its facilities
  • Advised on the shipping of nonhazardous pharmaceuticals
  • Advised on state and federal packaging and labeling requirements applicable to store brand pesticides
  • 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
  • Advised on compliance with EPA's e-Manifest program
  • Advised on a state administrative enforcement action regarding alleged air violations from a food manufacturing facility
  • Advised on a state administrative enforcement action regarding alleged stormwater and water quality violations from a food manufacturing facility
  • Advised on a local government's administrative enforcement action regarding alleged stormwater violations from a food manufacturing facility
  • Advised on a facility-wide environmental compliance audit, addressing air, water and waste issues, at a food manufacturing facility
  • Advised a food manufacturing facility regarding its compliance with Tier II hazardous chemical inventory reporting requirements, including its participation in EPA's small business audit disclosure program
  • Advised a food manufacturing facility on its appeal of a state environmental compliance history rating
  • Advised a food manufacturing facility with respect to its application for a stormwater permit
  • Advised clients on EPA's pharmaceutical waste regulations

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


  • 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

Publications & Presentations

  • Top 10 Things You Should Know About PFAS: Real Estate and Corporate Due Diligence, Synergy Environmental, Inc.  (2020)
  • PHMSA Proposes Rule Revisions for Hazardous Liquid Pipelines, Holland & Knight Alert(2020)
  • Top 10 Things You Should Know About PFAs: Real Estate and Corporate Due Diligence, Holland & Knight's Energy and Natural Resources Quarterly Newsletter: Spring 2020
  • TCEQ Guidance on Enforcement Discretion Requests for Operational Noncompliance Tied to COVID-19, Holland & Knight Alert (2020)
  • Michigan Workgroup Issues Health-Based Drinking Water Value Recommendations for PFAS in Next Step Toward Establishing Enforceable Limits, Holland & Knight Energy and Natural Resources Blog(2019)
  • Fifteen States and State Associations Comment on EPA’s Draft PFAs Guidance, Holland & Knight Energy & Natural Resources Blog (2019)
  • Michigan Governor Moves to Establish Enforceable PFAS Limits, Holland & Knight Energy and Natural Resources Blog(2019)
  • EPA's New Prescription for Pharmaceutical Waste, Holland & Knight Alert(2019)
  • Environmental Hazard Communications, Texas Environmental Law, Chapter 16, Thomson.
  • Used Oil Regulation, Texas Environmental Law, Chapter 22, Thomson Reuters (2007-Present)
  • Environmental Ethics and the Duty to Report, Texas Oil & Gas Association (TXOGA) (2018)
  • Rising Environmental Enforcement in the Food and Drug Sector: How to Stem the Tide for Your Facility, Synergy Environmental Newsletter(2017)
  • Home Grown: A Legal Guide to Starting a Nonprofit Farmers' Market in Texas, Texas C-Bar and Texas Rio Grande Legal Aid (2016)
  • Environmental Incident Response: Preparing for and Responding to the Unexpected, Client Alert(2015)
  • BLM Issues New Hydraulic Fracturing Regulations, Client Alert(2015)
  • EPA Publishes Proposed Rule: Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards, Client Alert(2014)
  • University Nano Labs: Assessing and Minimizing Environmental, Health & Safety Risks, Co-Author / Journal of College and University Law(2011)
  • Responding to NIOSH's Nanomaterial Exposure Limits, Client Alert(2011)
  • Emerging Safety Issues at University Nanomaterials Labs, Nanotechnology Law & Business(Winter, 2009)
  • Evaluating a Nanomaterial Operation's Compliance with Environmental Requirements: Selected Environmental Audit Statutes and Policies, Nanotechnology Law & Business(Summer, 2009)
  • Auditing as a Tool for Ensuring Compliance with Nanotechnology Safety Requirements, Nanotechnology Law & Business(Winter, 2008)
  • Nanotechnology Safety: A Framework for Identifying and Complying with Workplace Safety Requirements, Nanotechnology Law & Business (Summer, 2008)

Professional & Community Activities

  • State Bar of Texas 
    - Environmental & Natural Resources Law Section
    - Administrative & Public Law Section
  • Austin Bar Association
    - Environmental Law Section
    - Adoption Day Committee, 2019-present
  • American Bar Association
    - Section of Environment, Energy & Resources (SEER)
      - Environmental Enforcement & Crimes Committee
      - Water Resources Committee
      - Environmental Disclosure Committee
      - Environmental Transactions & Brownfields Committee
  • Texas State Bar College
  • 2020 Women on Boards, Austin, Texas
    - Host Committee
      - Awards Subcommittee, 2019
      - Program Subcommittee, 2019
  • The University of Texas, Chancellor's Council

Practice Areas