Paul Sarahan represents clients in the energy, chemical, manufacturing, transportation, technology and retail industry sectors on environmental issues. For more than two decades, Paul has been actively involved in the law, policy, regulation and commercial use of the environment. His experience includes civil and criminal enforcement, permitting, auditing, litigation, workplace safety, air quality, water rights, water quality, waste handling and disposal, and Superfund/CERCLA matters.
Paul has represented clients before the Texas Commission on Environmental Quality (TCEQ) and the U.S. Environmental Protection Agency (EPA), as well as before state environmental agencies in Louisiana, Mississippi, Florida, Georgia and Wyoming. Paul has handled matters before the Pipeline and Hazardous Materials Safety Administration (PHMSA), the Federal Aviation Administration and the Federal Railroad Administration.
Notably, Paul served as the director of the Litigation Division at the TCEQ from August 1998 to November 2005, and prior to that served as a senior attorney and as a staff attorney from July 1994 to August 1998. Paul was directly responsible for the TCEQ’s Environmental Audit and Supplemental Environmental Projects programs.
During his tenure at the TCEQ, Paul litigated complex environmental cases involving enforcement and permitting. Paul also assisted in rulemaking, compliance history, penalty policy, and emissions events issues, and testified before the Texas Legislature on environmental enforcement and compliance issues. He advised TCEQ’s Superfund, Voluntary Clean-up, Innocent Owner and PST programs. In addition, he supervised TCEQ’s criminal investigations unit, reviewed criminal cases brought by the state’s environmental crimes task force and served on the agency’s Homeland Security Task Force.
As a result of working at the TCEQ, Paul understands the processes and the people involved in any given matter, as well as what kinds of issues and facts are important to them. This unique experience has allowed Paul to build a reputation for trustworthiness when dealing with government agents.
Listed in The Best Lawyers in America© and Texas Super Lawyers, Paul is a “Recommended Attorney” by The Legal 500 US, one of the “Top Ten Experts in Environmental, Health and Safety Issues Related to Engineered Nanomaterials,” in Nanotechnology Law & Business, and included among “The In-House Crowd” in Texas Lawyer. Paul is an excellent writer and proven advocate who always stresses the importance of creativity, ingenuity and invention when solving problems that are seemingly impossible or mired in complexity. His consistently good judgment is grounded in solid legal theory, experience and practical business sense.
Outreach Committee, Episcopal Church of the Good Shepherd, chair
Healthcare for the Homeless, associate board
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 a petrochemical facility in emergency response activities related to multiagency investigations and enforcement actions.
Represented waste facilities in an administrative permitting hearing, and in related state district court litigation.
Engaged as an expert witness by industrial companies in civil environment enforcement litigation regarding TCEQ enforcement processes and procedures.
Represented clients in civil and criminal environmental enforcement actions brought by local governments.
Advised various oil and gas operations on TCEQ enforcement matters, including investigations related to operations in the Barnett Shale, air permitting matters, emissions inventory issues, greenhouse gas reporting requirements and Department of Transportation registration requirements.
Advised various pipeline operations on PHMSA enforcement matters.
Represented clients in administrative enforcement actions brought by the TCEQ and the EPA.
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.
Assisted clients in developing and implementing environmental audit programs addressing air, water, waste and EPCRA issues.
Advised clients on Occupational Safety and Health Administration (OSHA) requirements.
Represented a power plant in obtaining a reversal of a negative use determination on an application for an environmental tax exemption.
Represented clients in Superfund matters.
Represented a chemical company in handling a criminal investigation; succeeded in avoiding criminal charges and all civil and administrative enforcement actions were dropped.
Ranked as a leading practitioner in the Environmental area by Chambers USA, 2017.
The Best Lawyers in America© (Woodward/White, Inc.), Environmental Law, 2016 and 2018.
Named in 2014–2016 in the Environmental Law area by Thomson Reuters for Texas Super Lawyers.
Selected as a “Recommended Attorney,” The Legal 500 US by Legalese in the Industry Focus: Energy: Regulatory area; 2015.
“Top Ten Experts in Environmental, Health, and Safety Issues Related to Engineered Nanomaterials,” Nanotechnology Law & Business, 2009.
“The In-House Crowd,” Texas Lawyer, 2005.
College of the State Bar of Texas, member
State Bar of Texas; Environmental Law Section; Administrative Law Section; member
The University of Texas, Chancellor’s Council, member