Biography

Patrick Runge is an expert in environmental and safety compliance with deep experience in the federal and state air, water, waste, and worker safety regulations that impact the largest industrial facilities.  He advises companies, government bodies, and other parties in matters involving the U.S. Environmental Protection Agency (EPA), the U.S. Army Corps of Engineers, Occupational Safety and Health Administration (OSHA), the Federal Energy Regulatory Commission, the U.S. Department of Transportation (DOT), and their state counterparts.

Patrick’s work includes complex permitting issues involving air, surface water, groundwater, stormwater, and solid/hazardous waste, as well as self-auditing, remedial planning, and crafting strategies to address changing regulatory landscapes. Patrick also conducts EHS diligence and has been involved in over one hundred major transactions.

Patrick defends clients in both administrative and civil actions for facilities involved in state and federal enforcement actions involving alleged environmental or safety incidents.

Representative Matters

• Representing owner of major municipal landfill in overlapping criminal, civil, and administrative enforcement actions brought by the local U.S. Attorney, U.S. EPA, and various California sate agencies relating to waste disposal activities caused by elevated temperature events.
• Representing major midstream energy company in negotiations with other potentially responsible parties connected to legacy drilling waste disposal site in anticipation of imminent government issuance of a CERCLA administrative order allocating cleanup costs among multiple supermajor co-defendants.
• Successfully represented a major midstream energy company in overturning a proposed “debarment” by U.S. EPA arising from legacy conduct of an acquired subsidiary of the company, allowing the company to once again receive federal contracts.
• Representing a major fuel distributor in civil enforcement action brought by U.S EPA and the U.S. Department of Justice regarding compliance with Clean Air Act New Source Performance Standards and other regulatory requirements at a marine terminal with potential civil penalties of over $2 million.
• Representing coalition to file amicus brief in pending landmark US Supreme Court case arguing that Colorado’s attempt to apply state tort law to global greenhouse gas emissions violates constitutional principles by empowering individual states to dictate energy policy for the entire nation.
• Drafted rulemaking comments in support of rescindment of the U.S. EPA’s “Endangerment Finding” on behalf of oil and gas exploration, production, and technology group and related industry.
• Represented major Japanese forklift manufacturer and North American affiliates in criminal and civil enforcement actions brought by U.S. DOJ and U.S. EPA regarding allegedly false emissions data and other submissions underlying certificates of conformity, with potential penalties of more than $500,000,000.
• Represented various German automakers in U.S. DOJ enforcement and U.S. EPA enforcement actions and related compliance and certification matters.