Overview
With more than a decade of experience representing energy, industrial, and agricultural clients across the Rocky Mountain region and the Midwest, Randy counsels clients on Clean Air Act (CAA) permitting, compliance, and enforcement matters. His air quality practice encompasses New Source Review permitting, Title V operating permits, compliance audits, enforcement defense, and regulatory advocacy. His experience includes representing clients in national and significant air quality enforcement matters with the U.S. Environmental Protection Agency (EPA), the U.S. Department of Justice, and state environmental agencies, as well as in rulemaking proceedings shaping methane and emissions standards for oil and gas operations.
Randy's practice spans the full range of environmental regulatory work, including matters under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Clean Water Act, and the Resource Conservation and Recovery Act (RCRA). He represents clients in environmental litigation, permitting, regulatory compliance, transactions, brownfields, and site remediation, and has represented clients in federal and state litigation, including CERCLA cost recovery and contribution actions and citizen suits under the Clean Water Act and RCRA.
Randy also advises manufacturing and industrial clients in the Midwest on air quality compliance and permitting, applying the same regulatory depth he has built representing energy clients in the West.
Experience
Representative Work
- Represents data center in national air quality permitting and enforcement actions.*
- Represents upstream oil and gas operators in significant national air quality enforcement actions brought by the U.S. EPA and U.S. Department of Justice.*
- Represents oil and gas operators in major air quality rulemakings before the Colorado Air Quality Control Commission. *
- Represents oil and gas operators in major oil and gas rulemakings before the Colorado Energy and Carbon Management Commission.*
- Represents energy clients in enforcement actions brought by the Colorado Air Pollution Control Division and the Colorado Energy and Carbon Management Commission regarding alleged violations of air quality and oil and gas laws and regulations. *
- Represents oil and gas clients in enforcement actions brought by the North Dakota Department of Environmental Quality.*
- Represents midstream operators in air quality permitting in Wyoming.*
- Represented an agricultural client in negotiations with the EPA regarding alleged Clean Air Act Risk Management Program violations. *
- Represented an energy client in air quality permit appeal before the Pennsylvania Environmental Appeals Board. *
- Represented an energy client in rulemaking before the Colorado Water Quality Control Commission regarding revisions to water quality standards and classifications. *
- Represented a mining client in negotiations with the Colorado Water Quality Control Division regarding alleged discharge permit violations. *
- Represented clients in cleanup activities under CERCLA and state voluntary remediation programs. *
- Represented clients in major environmental litigation defense, including citizen suits under the Clean Air Act, the Clean Water Act, and RCRA, and cost-recovery and contribution actions under CERCLA. *
* Experience occurred prior to joining Dorsey.
News & Resources
News & Press Mentions
- “State Carbon Cost Disparities are Pivotal in Data Center Siting, Law360 (March 27, 2026)
- “Keys to Federal Carbon Compliance in Data Center Siting,” Law360 (March 26, 2026)
- “’Pulling Back the Curtain’ – EPA Proposing to Increase Transparency for Guidance Documents,” The Energy Law Advisor, Vol. 14, Number 3 (September 2, 2020)
- “Troubled Waters Ahead: CWA Rule Sure to Rock the Boat, Law360, (April 2014)
- “Clean Water Act Jurisdiction over Excavation Activities: The ‘Tulloch Rule’ Revised, The Colorado Lawyer, Vol. 38, No. 7, (July 2009)
Events & Speaking Engagements
- “Controlling Methane from the Upstream Oil and Gas Sector: Lessons from the Colorado Experience,” Air & Waste Management Association’s International Specialty Conference Addressing Climate Change (September 10, 2015)
- “Recent Developments in Federal and State Greenhouse Gas Regulation: Implications for Your Industry,” Rocky Mountain States Section, Air & Waste Management Association (September 2014)
- “Game Changer: New Colorado Air Quality Regulations for the Oil and Gas Industry, Rocky Mountain Association of Environmental Professionals Meeting, (March 2014)
- “Operating in a World of Nonattainment: National Ambient Air Quality Standards and Implications for Energy Development,” Rocky Mountain Mineral Law Foundation Special Institute: Air Quality Issues Affecting Oil, Gas, and Mining Development in the West, (February 2013)
