Molly Cagle

Senior Counsel

Molly Cagle Photo


P: +1.512.322.2535
F: +1.512.322.3635

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


  • 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


  • 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


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