Samuel L. Brown

Professional Biography

A former US EPA lawyer, Sam brings deep knowledge and practical experience to his clients’ environmental and natural resource concerns, helping them navigate the demands of regulatory agencies, ensure facility and corporate compliance, respond to government investigations and defend against enforcement actions.

Sam is experienced in domestic and international environmental and natural resource matters that impact client business and operations. His clients primarily include public and private sector manufacturing, mining, electric utility, oil and gas, municipal drinking water and wastewater utility, agriculture and land development companies. Sam’s clients are nationwide and they rely on his advice for compliance counseling, obtaining regulatory authorizations, facility and corporate audits, project and transactional due diligence, administrative and civil enforcement defense, and litigation.

Sam’s sophisticated approach to engaging with regulatory agencies and his deep knowledge of complex regulatory programs is grounded in his experience as a lawyer with the US EPA, in the Office of Regional Counsel in San Francisco (Region 9) and in New York (Region 2), and the Office of General Counsel in Washington, DC. His experience at EPA makes him effective and efficient at problem solving with federal and state regulatory agencies.

Sam focuses, in part, on multi-media government and third party investigations, incident response, and defending clients against government enforcement actions and NGO citizen suits.

In the US, his clients rely on his experience when navigating the Clean Water Act (CWA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Safe Drinking Water Act (SDWA), Resource Conservation and Recovery Act (RCRA); the Clean Air Act (CAA); the Toxic Substances Control Act (TSCA); the National Environmental Policy Act (NEPA); the Emergency Planning and Community Right-to-Know Act (EPCRA); the Endangered Species Act (ESA); and state-equivalent environmental, health and safety, and consumer product-related statutes.

For international matters, he is often called on to ensure facility and corporate consistency with Equator Principles and World Bank established International Finance Corporation (IFC) Performance Standards and manage legal, commercial and reputational risk.

Sam is frequently invited to speak and write on trending issues in environmental law, particularly the enforcement practices and operations of federal and state regulatory agencies. He also contributes regularly to the firm’s Nickel Report blog, which focuses on trends and developments in energy and environmental law.

He is a former adjunct professor and guest lecturer, including at the University of San Francisco, where he taught environmental law; Taras Shevchenko National University of Kyiv School of Law in Ukraine, where he taught on matters related to the oil and natural gas sector in Eastern Europe; Pace University School of Law; Golden Gate University School of Law; and The George Washington University School of Law, where he taught courses on environmental, energy and land use.

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