Steve provides manufacturing clients with strategic advice on many aspects of environmental law, in particular through a focus on counseling and enforcement defense on state and federal air emission issues. He routinely counsels clients on air permitting issues, including state installation and operation permits, New Source Review, Title V, New Source Performance Standards, and hazardous pollutant Maximum Achievable Control Technology standards.
In addition, he advises clients on solid and hazardous waste management and Resource Conservation and Recovery Act corrective action. Steve’s in-depth understanding of large-scale manufacturing operations such as iron and steel, chemical, utility, and petroleum refining forms the foundation for developing effective environmental compliance and enforcement defense strategies.
Convinced state and federal agencies on numerous occasions on the inapplicability of “credible evidence” in threatened enforcement actions involving allegations of noncompliance for opacity standards, including alleged noncompliance based on continuous opacity monitors.
Developed a successful strategy involving the imposition of an equivalent visible emissions limit for a combustion stack to negate injunctive relief sought by U.S. EPA in an enforcement action.
Successfully defended a paper mill in a U.S. EPA New Source Review enforcement action based on technical and engineering analyses that demonstrated increased emissions were not associated with any physical changes.
Successfully defended an integrated steel mill in a U.S. EPA New Source Review enforcement action based on a detailed netting analysis and a determination of the applicability of New Source Review exemptions.
Negotiated a Sulfur Dioxide State Implementation Plan Consent Order for a manufacturing facility that avoided the requirement for redundant controls during annual control device outages.
Permitted the removal of a costly thermal oxidizer control device from a manufacturing plant based on a demonstration of the balance of VOC emissions controlled versus emissions created from operation of the control device, and inapplicability of anti-backsliding considerations.
Successfully defended a glass manufacturing plant in a U.S. EPA New Source Review enforcement action based on Best Available Control Technology determinations and interpretation of condensable particulate matter requirements.
Convinced U.S. EPA to forgo RCRA corrective action at steel finishing facility and a coke-making facility due to lack of statutory authority.
Counseled companies on compliance with cap-and-trade program requirements, including program applicability determinations, initial allocation of emission allowances and credits, quality assurance/quality control monitoring obligations, and sufficiency of data reporting.
Assisted clients in remediation obligations pursuant to purchase agreements, closure plans, and consent orders.
University of Cincinnati College of Law, J.D., 1996
University of Cincinnati Law Review, 1994-1996
Indiana University, B.A., 1993
Certificate of Environmental Studies, 1993
Chambers USA, Natural Resources & Environment, 2008-2022
The Best Lawyers in America®
Environmental Law, 2010-2023; Cincinnati Environmental Law “Lawyer of the Year,” 2019, 2023
Litigation – Environmental, 2011-2023
Selected for inclusion in Ohio Super Lawyers Rising Stars®, 2006-2007, 2009-2011
Law360’s Top Ten Environmental Attorneys Under 40 to Watch, 2010