People

Overview

Harrison Reback is a go-to resource for federal and state Clean Air Act regulatory compliance counseling across the energy value chain. Harrison is well versed in the operational needs and environmental compliance issues for clients at the well head, across transportation and processing facilities, and downstream at refineries, chemical plants, and electric generating facilities.

Harrison represents clients in routine counseling matters and enforcement defense before EPA, PHMSA, OSHA, TCEQ, and Harris County, among other agencies. Through this work, Harrison has established particularly strong relationships with staff at EPA Region 6 and state environmental regulators in Texas, New Mexico, and North Dakota.

Harrison also routinely supports clients in crisis response activities and emergency response planning. Harrison has deployed to major incidents at well sites, gas plants, refineries, chemical plants, and other facilities outside the energy sector. Harrison has led initial response activities, interfaced with responding state and federal agencies, conducted incident and whistleblower investigations, and defended against resulting enforcement actions in the wake of fires, fatalities, and chemical releases.

Admissions & Affiliations

  • State Bar of Texas
  • Houston Bar Association, Environmental Law Section

Education

  • J.D., University of Virginia School of Law 2015
  • B.A., Environmental Science, University of Florida 2012
    cum laude

Experience

  • Exploration and production companies – supported responses to EPA Permian flyover notifications and negotiations of enforcement resolution
  • Exploration and production companies – represented clients in multiple New Mexico contested air permit hearings and secured final permits
  • Exploration and production company – developed comments and participated in New Mexico hearing for NMED ozone precursor rule
  • Refinery – advised on TCEQ regulatory requirements and led application for mitigation of compliance history score
  • Terminal company – resolved alleged violations of Harris County floodplain regulations
  • Pipeline company – advised client concerning potential regulatory and litigation risks associated with construction of new interstate pipeline project
  • Pipeline company – advised client on PHMSA jurisdictional determinations, regulatory obligations concerning pipeline abandonment, and enforcement risks
  • Pipeline company – supported enforcement defense concerning alleged noncompliance with federal air regulations 
  • Chemical company – advised on regulatory compliance with TCEQ air regulations and supported submittal of required reports
  • Terminal company – led incident response and defense for subsequent agency investigations including OSHA, CSB, EPA, TCEQ, and Harris County
  • Offshore operator – conducted internal investigation, disclosed potential violations pursuant to EPA Audit Policy, and received declination of prosecution from EPA
  • Terminal company – conducted internal investigation in response to allegations by a potential whistleblower
  • Pipeline company – facilitated company response following fire at Oklahoma facility
  • Pipeline company – conducted internal investigation following fatality and responded to agency investigations
  • Exploration and production company – led the development of a global consent decree to resolve violations of North Dakota air regulations for a number of exploration and production companies operating in the Bakken
  • Exploration and production company – assisted with response to EPA Request for Information under Section 308 of the Clean Water Act
  • Exploration and production company – Assisted in Section 408 and Section 404 permitting issues associated with a North Dakota pipeline project subject to delays by the U.S. Army Corps of Engineers
  • Exploration and production company – Advised on permitting and compliance issues associated with NEPA and the National Historic Preservation Act for a North Dakota pipeline project
  • Electric utilities – supported development of new power generation assets, including permitting obligations