Aron looks at every legal issue through the lens of his client's business.
He counsels clients on regulatory compliance and represents them in administrative proceedings and enforcement actions related to air, waste, water, and safety issues. He has experience in a broad array of industry sectors ranging from petroleum refineries to data centers and advises one client in the iron and steel industry on its day-to-day environmental issues affecting several facilities throughout the country.
In the course of advising clients on regulatory issues, Aron has saved companies millions of dollars by working with corporate engineering teams to identify solutions that maintain environmental compliance in the most efficient manner possible. His experience includes all major programs under the Clean Air Act (CAA), complex hazardous waste issues under the Resource Conservation and Recovery Act (RCRA), permitting issues under the Clean Water Act (CWA), and a number of Occupational Safety and Health Administration (OSHA) standards, including the new respirable crystalline silica standard.
In administrative proceedings, Aron assists clients with navigating various issues throughout the CAA permitting process, including challenging unjustified requirements and responding to comments from Environmental Protection Agency (EPA) and citizen groups. He also has drafted comments on several administrative rulemakings. In one matter, Aron negotiated with EPA a 70% reduction in the cost of stack testing required as part of a Residual Risk and Technology Review of certain CAA Maximum Achievable Control Technology (MACT) standards.
Aron’s experience in enforcement matters includes negotiating and drafting consent decrees, responding to Notices of Violation (NOVs), and crafting responses to CAA § 114 and RCRA § 3007 requests for information. Representative matters include successfully resolving multiple NOVs in a high-profile and very favorable consent decree, forestalling the issuance of an NOV by proactively addressing a failed stack test, and significant experience with EPA’s Refinery Initiative and related flaring issues.
Aron also has significant litigation experience in CAA and RCRA citizen suits, including drafting dispositive motions, assisting with preparation of expert reports, and managing electronic discovery teams.
