Environmental Law

Angela Morrison is a well-respected expert in administrative law

with over 30 years of experience in environmental and land use law.

Her clients range from established regulated utilities to entrepreneurial independent power

producers, and from global corporations to small venture capital startups. Angela realizes the

potential implications associated with non-compliance, and strives to provide her clients with

pertinent and relevant information to help navigate the applicable programs and rules. She

works to provide the personal and prompt attention each client needs regardless of their size.

INDUSTRIES

With the Clean Air Act’s broad reach, it has impacted virtually all stationary air emission sources in one way or the other over the years. This has given Angela an opportunity to represent an array of diverse clients and, in a growth state like Florida, provided a virtually unparalleled opportunity to be involved with an impressive variety of facilities being constructed, operated, expanded, modified, converted, or relocated, including some of the first large-scale biomass and alternative fuel projects to be permitted in the state. Industries served by Angela over the past 30 years include:

Acid plants

Aluminum recyclers

Amusement and theme parks

Asbestos removal projects

Aggregate production facilities

Agricultural operations

Asphalt plants

Battery manufacturing

Biofuel and biogas manufacturing

Biomass facilities

Boat manufacturing and shipbuilding

C & D recycling facilities

Cement manufacturing

Chemical manufacturing

Citrus production and processing

Coffee roasting operations

Concrete batch plants

Drycleaners

Flavoring and fragrance companies

Foam products manufacturing

Furniture manufacturing

Glass manufacturing

Landfills

Landfill gas-to-energy facilities

Medical waste processing/disposal

Mining operations

Natural gas compressor stations

Natural gas pipelines

Nylon fiber manufacturing

Petroleum storage facilities

Pharmaceutical manufacturing

Phosphate fertilizer manufacturing

Power plants of all types

Pyrolysis technology

Refrigeration facilities

Sandblasting operations

Ship transfer operations at ports

Soil thermal treatment facilities

Steel coating facilities

Steel recycling facilities

Sulfuric acid plants

Wastewater treatment plants

Waste to energy facilities

To help keep her clients informed and to consider potential industry impacts, Angela has actively monitored Florida and federal legislative and regulatory actions related to air emissions, climate change, and stationary sources since the 1990 Amendments. She routinely assists clients with seeking improvements to state and federal rules to ensure that their interests are being appropriately considered, to help raise awareness of potential consequences, and to minimize unnecessary adverse economic impacts.

Given the complexity of large projects and her organizational skills, Angela routinely leads teams of client representatives and consultants on projects that vary from commenting on major federal rulemakings, to proposed new greenfield developments, to significant federal enforcement cases.

EXPERIENCE

Almost immediately after Angela began practicing law, she became an authority on the implementation of the 1990 Clean Air Act Amendments through the representation of utility and industry clients. She continues to be one of the leaders in this field. She also has knowledge and experience with many other areas of environmental law as well as with local land use laws through her representation of utility clients siting new generating facilities under the Power Plant Siting Act. Over the years, her practice grew to include broad environmental and land use representation on behalf of a wide variety of industry, manufacturing, developer, trade association, and government clients, which is reflected in the list of practice areas below. Angela routinely assists with environmental-related legislation, rulemaking, permitting, variances, waivers, recordkeeping and reporting, compliance, enforcement, administrative litigation, appeals, and audits at federal, state, and local levels on behalf of industry, utility, and government clients.

PRACTICE AREAS

Air Quality—Title V air operation permits, New Source Review permitting (PSD and Nonattainment NSR), state and federal emission standards (including NSPS and NESHAPs), Florida's State Implementation Plan, Florida's 111(d) Plans, CISWI, Risk Management Plans, federal and state ambient air quality standards, acid rain program, regional haze, air toxics, ozone and lead nonattainment programs, emissions trading programs, PSD increments, mobile source programs, BACT and RACT emission standards, air quality monitoring and modeling, fugitive sources, continuous monitoring requirements, minor source permitting, general air permits, de minimis emissions and permit exemptions, NSR enforcement initiative defense and responses to 114 requests.

Climate Change—sustainability, greenhouse gases, emission standards, cap and trade programs, emission reporting, federal carbon dioxide emission standards for utilities, risk assessments, the Tailoring Rule and implementation of the PSD program for greenhouse gases.

Site Certification—environmental and land use approvals for generating and linear facilities need for power determinations and Public Service Commission approvals, Florida Electrical Power Plant Siting Act, Transmission Line Siting Act, modifications, post-certification amendments.

Health Risk Assessments—single and multi-pathway, acute and chronic exposures, threshold criteria.

Release Reporting—hazardous substance reporting under federal programs such as EPCRA and CERCLA, continuous and permitted releases, State Warning Point, annual operating reports, inventories, and Florida's relatively new Pollution Incident Reporting Program.

Renewables—crops; incentives, grants, and loans; expedited permitting; ethanol and biodiesel manufacturing and dis-tribution; Renewable Portfolio Standards; cap and trade programs.

Due diligence—for asset purchases, appropriate inquiries, asset retirement, financial assurance, disclosures.

Tax credits and exemptions—for renewable energy, manufacturing, and pollution control equipment.

Water—consumptive use, industrial and thermal discharges, mixing zones, entrainment, and impingement, impacts from air emission deposition, water quality standards for groundwater, surface, and drinking water.

Waste—alternative fuels, comfort letters, non-hazardous secondary material determinations, tires, storage, trans-portation, conversion and reuse, reduction goals, coal ash.

Wetlands—mitigation and mitigation banks, jurisdictional determinations, potential impacts, waters of US.

Endangered Species—listings, habitat, potential impacts, permits, mitigation, takings.

Agricultural-related approvals—energy crops, non-native species, biomass processing.

Local noise, odor, and other nuisance ordinances—including special exceptions, variances, and code enforcement.

FORUMS