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Bob Greenslade

Counsel

Bob Greenslade

Denver

T:+1 303 801 2747

Houston

T:+1 713 651 5360

Bob Greenslade is Counsel in the Denver and Houston offices. His legal practice focuses on multi-media environmental matters, with an emphasis on air issues, including state and federal air compliance and permitting, enforcement matters, corporate due diligence and climate change. Bob's experience includes consent decree negotiation and compliance, environmental audits, noncompliance disclosures and corrective action negotiations, as well as Title V and New Source Review permitting and compliance. Areas of concentration include upstream and midstream oil and gas facilities, refineries, chemical plants, power plants, and miscellaneous manufacturing.
 
A chemical engineer by degree, Bob was a petroleum engineer and an environmental consultant prior to attending law school and joining Norton Rose Fulbright. His prior oil and gas work experience includes reservoir management and planning and oversight for drilling, workovers, and stimulation procedures, including hydraulic fracturing. As a consultant, Bob worked extensively on environmental criminal defense, audits and regulatory applicability, the Benzene Waste Organic NESHAP, Section 114 requests, and other air compliance issues. He also has technical experience with emissions calculations and reporting, and environmental compliance management systems.
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  • Education

    2006 - J.D., High Honors, The University of Texas School of Law
    1996 - B.S., Chemical Engineering, Rice University

    While attending law school, Bob was a member of the Texas Law Review and was inducted into the Chancellors, UT Law's highest honor society. Bob is also a member of the Order of the Coif.

  • Representative experience

     Air Compliance and Permitting

    • Representation of an oil and gas client regarding air standards and permitting issues, including Tribal NSR, NSPS Subpart OOOO, and source aggregation concerns
    • Representation of a midstream client regarding air permitting, audit, and enforcement issues for numerous sites
    • Representation of an energy utility regarding regulatory compliance issues, including citizen suit litigation over permit authorizations and MACT compliance
    • Representation of an energy utility client regarding audit of startup emissions issues and associated disclosures to regulatory agencies
    • Representation of an oil and gas client regarding Clean Air Act source aggregation issues associated with a proposed LNG facility
    • Representation of a refining client regarding multiple audits under the Texas Environmental, Health, and Safety Audit Privilege Act (covering compliance with air permit emissions limits, the Benzene Waste Organics NESHAP, LDAR, emissions reporting, and other compliance issues)
    • Representation of a cement industry client regarding requests to the TCEQ and the U.S. EPA seeking a waiver of NSPS stack testing requirements

    Enforcement

    • Air emissions enforcement matters by the TCEQ, CDPHE, PA DEP, and SCAQMD for the oil and gas, chemicals, and manufacturing industries
    • Representation of a refining client regarding Section 114 information requests and associated stack testing and multiple U.S. EPA enforcement matters
    • Representation of an oil and gas client regarding a consent decree with the U.S. EPA and the U.S. DOJ
    • Representation of a midstream CO2 processing and pipeline company regarding audit disclosures, a negotiated compliance plan, and other enforcement matters
    • Representation of a midstream client regarding numerous TCEQ enforcement issues, including negotiating agreed orders and proposed penalties
    • Criminal enforcement matters for a crude-by-rail facility and chemical plants

    Climate Change/Carbon Sequestration

    • Representation of an energy company regarding PSD permitting requirements for a proposed LNG facility, including BACT issues for GHG emissions
    • Representation of a research and development facility regarding comments on and exemption from the U.S. EPA's Greenhouse Gas Emissions Inventory rule
    • Representation of a client regarding a feasibility study for a coal mine, coal-to-liquids, and carbon sequestration project; representation included a multi-state assessment of environmental, climate change, energy, and mining regulations and incentives for advanced/clean coal and carbon sequestration projects

    Corporate Transactions

    • Representation of a foreign investor regarding oil and gas production assets in California and Texas
    • Representation of renewable energy companies during the acquisition of active and proposed wind farm, solar, and hydro power assets
    • Representation of an energy company for the construction financing of a 37.5 MW biomass power plant
    • Representation of a large municipality in the acquisition of an 800-MW natural gas-fired combined cycle power plant facility
    • Representation of a private equity fund client on a joint venture for development and production of lease rights in Pennsylvania and West Virginia
    • Representation of an energy utility company with environmental due diligence and in drafting environmental provisions for a financing agreement
    • Representation of insurance underwriters regarding assessment of environmental due diligence risks

    Miscellaneous

    • Representation of a mining company with respect to federal and state environmental and safety requirements, including MSHA, for exploration and field operations.
    • Representation of an industry association regarding legal jurisdictional comments on well flaring and venting rulemaking by the BLM
    • Representation of an industry association regarding legal, technical, and economic comments on hydraulic fracturing regulations proposed by the BLM
    • Representation of oil and gas companies regarding potential tort and regulatory liabilities associated with transporting crude oil by railcar
    • Representation of oil and gas company regarding disposal of NORM and TENORM wastes associated with hydraulic fracturing and production activities
    • Representation of LNG clients concerning NEPA issues associated with DOE and FERC approvals for multiple LNG export facilities
    • Representation of a manufacturing client regarding potential environmental liabilities for blow out preventers used in offshore drilling
    • Representation of a crude oil marketer regarding potential environmental liabilities associated with a proposed business plan
  • Admissions
    • Colorado State Bar License
    • Texas State Bar License
  • Rankings and recognitions
    • Judge Suzanne Covington Pro Bono Service Award, Volunteer Legal Services of Central Texas, June 2012
    • Texas Rising Star, Environmental Law, Thomson Reuters, 2010 - 2011
  • Publications
  • Speaking engagements
    • "Methane in the Oil Patch," Texas Environmental Superconference, Austin, Texas, August 2015
    • "Air Quality Challenges for Oil & Gas Operators," Breakfast Speaker Series, Denver Petroleum Club, Denver, Colorado, October 2012
    • "Air Issues Surrounding Mining Operations," Regional Mining Conference, Colorado Hazardous Waste Management Society, Denver, Colorado, October 2012
    • "EPA Air Update," 2012 Environmental Law Update Seminar, Houston, Texas, September 2012
    • "Clearing the Air:  Issues Around Your Power Project," Fulbright Webinar, Austin, Texas, June 2012
    • "Air Developments and Issues," 2011 Environmental Law Update Seminar, Houston, Texas, October 2011
    • "Industry Focus, Part I:  Exploration and Production and Midstream Activities," University of Texas CLE Air Quality Seminar, Austin, Texas, November 2010
    • "EPA and RCRA/Solid Waste Enforcement Update," 2010 Environmental Law Update Seminar, Houston, Texas, October 2010
    • "Geologic Carbon Sequestration in Texas: Statutes, Regulations, and the Common Law," The University of Texas 2010 Carbon and Climate Change Conference, University of Texas CLE, Austin, February 2010
    • "EPA Update," 2009 Environmental Law Update Seminar, Houston, Texas, October 2009
    • "Geologic Carbon Sequestration (Technical and Legal Hurdles)," 2008 Environmental Law Update Seminar, Houston, May 2008
    • "Climate Change and the Federal Clean Air Act," The University of Texas 2008 Carbon and Climate Change Conference, University of Texas CLE, Austin, April 2008
  • Memberships and activities
    • Colorado Environmental Management Society
    • Colorado Oil & Gas Association
    • Western Energy Alliance
    • Denver Petroleum Club
  • Publications

    US EPA issues climate change regulations for oil and gas

    On May 12, 2016, the U.S. Environmental Protection Agency issued New Source Performance Standard Subpart OOOOa, the agency’s climate change regulations for methane and volatile organic compound emissions for the oil and natural gas sector. Subpart OOOOa for the first time specifically regulates methane emissions from the oil and gas sector. The regulation’s substantive provisions will impose costly compliance burdens on industry. As examples, the rule extends Reduced....

    May 13, 2016

    EPA targets oil and gas methane emissions

    On August 18, 2015, the U.S. Environmental Protection Agency (“EPA”) fired another salvo in the agency’s efforts to combat climate change, proposing....

    August 19, 2015