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Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes internal investigations, responding to grand jury investigations and agency information requests, and negotiating consent, probation, and debarment agreements. He is currently the EPA Independent Monitor overseeing the nation’s largest investor-owned energy company’s compliance with complex debarment and probation agreements arising from the resolution of a criminal enforcement case brought under the Clean Water Act.

Chris assists buyers, sellers, investors and financial institutions on the environmental aspects of transactions, including conducting due diligence, negotiating the environmental provisions of transactional documents, and identifying and executing insurance-based risk management opportunities. His transactional experience has included upstream, midstream and downstream energy projects, alternative energy projects, and transactions in the manufacturing, logistics, consumer products and chemicals sectors.

He helps clients evaluate and implement compliance and ethics programs (e.g., under the Sentencing Guidelines), and environmental, health and safety management systems (including based on ISO 14001). Chris advises clients on sustainable development, climate change, product and chemical stewardship and regulation, and value chain management. He recently served on an independent committee advising the senior management of a Fortune 50 company on its global sustainability strategy and reporting.

This article is an effort to hit the “reset” button on the frequently breathless commentary on the recently argued Supreme Court case (West Virginia et al v. EPA) addressing
Continue Reading Journey to the U.S. Supreme Court – Regulating Power Plant Greenhouse Gas Emissions

In yet another “sue and settle” case, the U.S. Environmental Protection Agency has proposed entering into a consent decree agreeing to rule on the Center for Biological Diversity’s (CBD) petition
Continue Reading EPA Considers Classifying Discarded PVC Plastic as Hazardous Waste

The Biden-Harris administration is quickly establishing new federal environment requirements affecting commercial property owners and managers. These requirements, along with changes occasioned by the COVID-19 pandemic, raise a host of
Continue Reading The Top 5 New Environmental Issues for Commercial Property Owners or Managers

The incoming Biden Administration intends to take many major environmental policy actions   aimed at climate change, enforcement, environmental justice, and several other issues, many of which entail reversing actions taken
Continue Reading TRANSITION THOUGHTS: What Clean Air Act Permittees Should Track in the Biden Administration

In addition to causing infection and illness, the COVID-19 pandemic is creating challenges for organizations contending with employee quarantines and isolation, supply chain and logistics disruptions, and other operational changes.

While environmental compliance may not be top-of-mind right now for most Americans, it still is a critical consideration for organizations with environmental compliance or cleanup obligations.

Many environmental laws and settlement agreements provide relief valves in certain emergency or force majeure situations. But given that the regulators themselves may be quarantined or teleworking in the coming weeks and months, organizations can take certain steps now to ensure they are able to maintain environmental compliance during the COVID-19 pandemic or to obtain relief based on force majeure, impossibility or impracticability of performance, compliance-with-all-laws clauses, enforcement discretion, or emergency relief provisions.
Continue Reading Meeting Environmental Compliance and Cleanup Requirements During the Pandemic

The Environmental Protection Agency recently announced a final rule rescinding major amendments to the Clean Air Act §112(r) Risk Management Program (RMP) regulations that were promulgated at the end of


Continue Reading EPA’s Final Risk Management Program Reconsideration Rule More In-Step with OSHA’s Process Safety Management Standards