Environmental Law & Compliance Defense · Est. 1997
When the Notice of Violation Arrives,
We’re Already Prepared.
Counsel represents general counsel at mid-cap manufacturers, real estate developers navigating wetland mitigation, and municipal utilities facing new contaminant limits. We draft the compliance strategies that keep facilities operating and enforcement actions from becoming consent decrees.
The Attorneys
Each partner carries a distinct regulatory biography. The depth of the bench becomes apparent only after you meet each one.
Margaret R. Hollis
Founding Partner
Margaret built the firm's Clean Water Act practice from a single NPDES permit challenge in 1997 into a 28-attorney department that has defended manufacturers in 17 states. She spent four years as senior enforcement counsel at EPA Region 5 before crossing to the defense bar — a vantage point that shapes every consent order negotiation she leads.
Her landmark challenge to EPA's 2019 "Waters of the United States" rule established jurisdictional precedent that shielded three mid-Atlantic industrial clients from $340 million in remediation obligations. She has testified before the Senate Environment and Public Works Committee twice.
David E. Okafor
Senior Partner
David's CERCLA practice has recovered more than $680 million in cost allocation proceedings over eighteen years. He developed the firm's quantitative contribution analysis methodology — now the standard approach for multi-party Superfund negotiations — and has served as lead counsel in four National Priority List site remediation disputes.
In 2023 he secured a complete dismissal of CERCLA liability for a regional chemical distributor that had been named as a potentially responsible party at the Kalamazoo River Superfund site. The ruling turned on a chain-of-title argument he had been building for six years.
Claire T. Nakamura
Partner
Claire leads the firm's air quality practice, focusing on Prevention of Significant Deterioration permitting, Title V compliance, and New Source Performance Standards challenges. Before joining Counsel she clerked for the D.C. Circuit and spent three years in the Clean Air Markets Division at EPA headquarters.
In 2024 she reversed a Title V permit revocation that had halted production at a Pittsburgh-area steel mill, restoring $90 million in annual operating capacity. The administrative appeal succeeded on a procedural notice deficiency she identified during the initial permit review — a deficiency the agency's own record failed to correct.
Jerome A. Weston
Partner
Jerome built the firm's ESG and climate disclosure practice as SEC climate rulemaking accelerated. He counsels Fortune 500 manufacturers and private equity portfolio companies on Scope 1–3 emissions accounting, physical risk disclosure, and the intersection of federal climate rules with state environmental enforcement.
He developed the firm's proprietary PFAS risk-mapping methodology, deployed across fourteen municipal utility clients facing EPA's 4 ppt maximum contaminant limits. Three of those utilities have used the methodology to negotiate phased compliance schedules that defer capital expenditure by an average of 22 months.
Practice Areas
The regulatory landscape
we navigate daily.
Clean Water Act
NPDES permit defense, Section 404 wetland jurisdiction, navigable waters determinations, and stormwater enforcement response.
CERCLA & Superfund
Potentially responsible party defense, cost recovery litigation, multi-party contribution allocation, and consent decree negotiation at NPL sites.
Clean Air Act
Title V operating permit defense, PSD and NSR permitting, New Source Performance Standards challenges, and greenhouse gas reporting.
ESG & Climate Disclosure
SEC climate rule compliance, Scope 1–3 emissions accounting, physical risk materiality analysis, and state climate disclosure obligations.
PFAS Regulatory Defense
Maximum contaminant level compliance planning, municipal utility negotiations, PFAS site liability assessment, and phased compliance scheduling.
Transactional Due Diligence
Phase I and II environmental assessment oversight, purchase price adjustment strategy, indemnification structuring, and post-closing compliance obligations.
Selected Results
The record speaks
before the ask.
Past results do not guarantee future outcomes. Case descriptions are illustrative of representative matters.
Title V Revocation Reversal
Pittsburgh-area steel mill
$90M operating capacity restored
PADEP / EPA Region 3
CERCLA § 107 Dismissal
Regional chemical distributor
$14M liability eliminated
EPA Region 5 / D. Mich.
WOTUS Jurisdictional Ruling
Mid-Atlantic industrial group
$340M remediation avoided
EPA / Army Corps / 4th Cir.
Wetland Mitigation Banking
NJ real estate developer
340-acre parcel cleared
Army Corps of Engineers
Consent Decree Withdrawal
Ohio auto parts manufacturer
Full enforcement withdrawal
EPA Region 5 / DOJ ENRD
NPDES Multi-Facility Defense
Midwest food processing company
Penalty reduced 94%: $3.8M → $220K
EPA Region 7