Insider insights help clients comply as they innovate
When you must comply with strict regulatory environmental standards, you want a former government insider guiding you every step of the way. Our team is led by the OhioEnvironmental Protection Agency’s (OEPA) former managing attorney for air and water programs, Bill Hayes. A widely recognized authority on the Clean Air Act, Bill also served in a role as the in-house environmental attorney for a top international OEM before joining Frost Brown Todd.
- Resource Conservation and Recovery Act (RCRA)
- Clean Air Act (CAA), including Title V operating permits, New Source Review construction permits and Section 114 information responses
- Clean Water Act (CWA)
- Toxic Substances Control Act (TSCA)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
As Tier suppliers and OEMs continually innovative, they must understand how their new installations, expansions, products, systems, facilities and more will impact the environment and proactively develop strategies to mitigate those impacts, including:
- Hazardous waste and solid waste management
- Industrial wastewater streams
- Air Emissions
- Storm water
- Hazardous materials transportation
- Wetlands mitigation and banking
- Cleanup liabilities for hazardous waste sites
We have spent decades on automotive manufacturing floors. We know what the equipment is and how it works. Our advice is grounded in a real-world understanding of your world.
- Proactive change review - Before you modify operations, we can quickly and effectively evaluate the impact on compliance and environmental regulations, providing innovative solutions that maximize operational flexibility, minimize waste and avoid unnecessarily stringent permit conditions when possible.
- Plant audits - We will walk the plant floors, review all manufacturing operations, permits, record keeping and reporting and applicable standards to ensure systems are in place to maintain current and ongoing compliance.
- Compliance audit program development - We assist OEMs in creating environmental management and compliance audit programs for their supplier networks.
- Enforcement defense - Should a company face a state or federal Notice of Violation — from wastewater discharge exceedances to hazardous materials spills to Clean Air Act Section 114 information requests — our team can help determine the options and the best course of action in order to avoid any production disruption, minimize exposure and provide counsel every step of the process.
- Creative solutions - We are widely known for our creativity. For example, when a groundbreaking manufacturing process for a hybrid supercar made it nearly impossible to comply with current regulations that never anticipated the new materials and production methods, we successfully worked with the regulators to change the rules to account for these new advances.
- Permitting strategies - We assist OEM’s and suppliers in obtaining a wide variety of permits for new and expanding operations under all media programs, including New Source Review, Title V, and plant-wide applicability (PAL) permits under the Clean Air Act, Clean Water Act industrial discharge and storm water permits, wetland mitigation permits, to name a few.
When a state regulatory agency sought to mandate permitting for full-vehicle dynamometer operations as stationary sources, we represented an automotive manufacturer in challenging the mandate. The result: a full revision of the rules and exemption of full-vehicle dynamometers at automotive manufacturing facilities from stationary-source permitting.