Molly Cagle

Clean Air Act

• Secured first contested NSR/PSD permit in non-attainment area (TCEQ decision upheld by district court
• Counseled clients on impact of non-attainment designation on permitting issues
• Represented clients in work group to consider challenging EPA’s eight-hour ozone non-attainment designation for counties determined to be “contributing to” non-attainment area
• Advised Dallas/Ft. Worth area client on 11 technical factors used by EPA in determining boundaries for eight-hour ozone non-attainment designations
• Evaluated emission credit contracts and transactions related to emission off-sets
• Reviewed and commented on various SIP issues associated with Houston, Galveston and Beaumont/Port Arthur ozone non-attainment areas
• Evaluated numerous computer modeling efforts and results in conjunction with various contested air permits
• Worked extensively with engineers, modelers and toxicologists in air modeling issues
• Advised client on viability of challenging TCEQ NOx rules
• Counseled clients on various Title V compliance issues

Mining

• Counseled clients on rulemaking and interpretation of coal combustion byproducts
• Represented client in defeating an unsuitability petition
• Assisted in securing settlement in SCMRA contested case
• Worked with a team of lawyers to permit a lignite mine in Texas

Water/Wastewater

• Secured, defended and defeated water rights permits
• Secured groundwater permits in contested matters from the Edwards Aquifer Authority and other groundwater districts
• Represented client in securing contested wastewater permit for new lignite mine
• Counseled clients on Effluent Limitation Guidelines for various industry sections
• Represented clients in contested TPDES wastewater discharge matters
• Challenged special districts on authorization to supply services
• Defended action to compel water supply
• Advised clients regarding water rights and water contracts in various transactions
• Advises on clean water cases, including those dealing with raw water supply
• Actively involved in Texas water planning efforts

Waste

• Permitted and renewed underground injection control
• Advised clients on various RCRA issues