Debra Jezouit is a partner and the Deputy Department Chair of the Environmental Department in the Washington office. She is widely recognized for her experience in Clean Air Act and Climate Change issues, representing clients in multiple industries, including electric generating companies, cement manufacturers, iron and steel foundries, pharmaceutical companies and chemical companies. She handles such matters as New Source Review and New Source Performance Standard compliance counseling, applicability determinations and enforcement, counseling on hazardous air pollutant requirements, acid rain compliance, emissions monitoring issues, air permitting at the state and federal level and the development of and compliance with emissions trading programs.
Ms. Jezouit participated extensively in the regulatory development process for the Clean Air Act’s Acid Rain Program and led negotiations with the Environmental Protection Agency on the development of various revisions to acid rain regulations. She has worked with the EPA on standards for air toxic emissions for several industrial categories, New Source Review rule reform, revisions to the New Source Performance Standards for electric generating units and Portland cement plants, and existing source performance standards for greenhouse gas emissions from electric generating units as well as several other rulemakings related to Clean Air Act programs. Ms. Jezouit has managed internal audits for several clients to evaluate their compliance with various Clean Air Act programs, including greenhouse gas reporting requirements, National Emissions Standards for Hazardous Air Pollutants and ozone depleting substances requirements, and she has assisted clients both to establish and periodically revise their internal procedures for analyzing New Source Review applicability. In addition, she has written and spoken extensively on New Source Review issues, including conducting New Source Review workshops for various clients. She also has extensive experience in responding to EPA investigations of alleged Clean Air Act violations and has negotiated several settlements of alleged Clean Air Act violations at the state and federal level, as well as with environmental groups.
- Portland cement companies – representation in appeals of National Emissions Standards for Hazardous Air Pollutants for the Portland cement industry, which resulted in more reasonable air toxics standards for the industry and an extension of the compliance deadline by two years (Portland Cement Association v. EPA (D.C. Cir. 2011) and Natural Resources Defense Council v. EPA (D.C. Cir. 2014))
- U.S. v. Holcim (US) Inc. (D.Md) – represented Holcim (US) Inc. in an enforcement suit brought by EPA for alleged Prevention of Significant Deterioration requirements under the Clean Air Act and negotiated a favorable settlement of the case for the client prior to trial
- Sierra Club v. The Dayton Power and Light Company, et. al (S.D. Ohio) – represented three co-owners of a power plant on alleged violations of the Prevention of Significant Deterioration, New Source Performance Standards and opacity requirements of the Clean Air Act and successfully negotiated a settlement of the case prior to trial
- Reliant Energy – representation in New Jersey v. Reliant Energy Mid-Atlantic Power Holdings, et. al (E.D. Pa), regarding alleged violations of the Prevention of Significant Deterioration and Title V permitting requirements of the Clean Air Act
- Major pharmaceutical company – successfully negotiated settlements of potential Clean Air Act violations at several facilities that were discovered as a result of internal audits and during an EPA investigation
- Class of ‘85 Regulatory Response Group – representation of a large coalition of electric generating companies regarding issues arising under the Clean Air Act and other environmental statutes, including providing analyses of regulations and development of comments on various rulemakings
- Power Generation Company – Representation before the U.S. Court of Appeals for the Third Circuit in an appeal of an EPA order regarding the company’s Title V permit
- Power Generation Companies – Design and assist in implementation of New Source Review compliance programs for fossil-fuel fired power plants
Awards & Community
Publications, Speeches & Presentations
Baker Botts Environmental Seminar
The Road Ahead on Key Clean Air Act Initiatives: Climate Change, Regional Haze, NAAQS and SSM SIP CallSpeeches & Presentations
Baker Botts Environmental Seminar
The Class of ’85 Regulatory Response Group will hold its first quarterly meeting of the year on February 1, 2018.
Donald Trump's election promises to have a major impact on U.S. environmental policy, as the President-elect has made no secret of his belief that American businesses are overregulated.