Title II of the Clean Air Act mandates extensive regulation of mobile sources of air pollution and the fuels upon which they operate. Mobile sources include on and off-road motor vehicles, boats, trains, airplanes, and a wide-range of smaller engines and equipment, including those used in lawn-movers, handheld gardening tools, and other similar equipment. The fuels used in these mobile sources include (or have included) leaded and unleaded gasoline and diesel fuel, as well as a wide-range of fuel additives for use in those fuels. Similar regulatory programs exist in other parts of North America, Europe, Asia and Africa, and elsewhere around the globe.

I have extensive experience in nearly all facets of the U.S. mobile source regulatory program, as well as similar programs around the globe. My representation of clients in the mobile source and fuel practice area starts with a fundamental premise – the recognition that mobile sources and the fuels upon which they operate are effectively “a unified system.” As such, I recognize that a thorough understanding of the regulatory frameworks governing both mobile sources and the fuels on which they operate is essential for a sound assessment of any proposed regulatory controls for either component of the “system.”

Domestically, I have been engaged to address:

Moreover, because many of these proceedings have involved complex technical questions relating to the testing and evaluation of motor vehicles and fuels, I have extensive experience working closely with technical experts and helping to prepare expert technical reports for review by administrative or judicial authorities. These technical reports have addressed all of the major components of vehicle emission control systems, including catalytic converters, oxygen sensors, spark plugs, and fuel injectors, among others, and have evaluated how the performance of emission system components change as fuel composition changes. Many of these technical reports have also addressed the environmental and air quality impacts of fuel-driven changes in vehicle emission performance.

Internationally, I have participated in mobile source regulatory initiatives in Canada, Mexico, the European Union, Asia, and Africa. These regulatory initiatives have addressed fuel composition issues and motor vehicle performance requirements both in the developed and developing world.

The breadth of my experience is reflected in the following list of significant matters I have handled over the past two decades (Note: The results in any particular case depend upon a variety of factors unique to each case; the case results presented below do not guarantee or predict a similar result in any future case.):


Regulatory Activity

International Regulatory Activity

Commercial Activities


Title I of the Clean Air Act establishes a detailed program for the establishment, attainment, and maintenance of National Ambient Air Quality Standards (‘NAAQS’). NAAQSs are set at a level designed to protect the public health and welfare with an adequate margin of safety. To attain and maintain compliance with the NAAQSs, Title I establishes a detailed federal/state partnership and a range of control measures for limiting pollution from new and existing stationary sources, which include most industrial facilities, such as manufacturing plants, electric power producing facilities, petroleum refineries, iron and steel plants, and smelters, among others. New industrial sources generally have to meet technology-based, “New Source Performance Standards,” while existing sources must meet either “Best Available Control Technology” (BACT) standards under the prevention of significant deterioration (PSD) program, or “Best Available Retrofit Technology” (BART) under the regional haze program, or both.

As with my Title II experience, I have extensive administrative and judicial experience dealing with Title I issues. Listed below are examples of my experience:


In addition to my experience with the Clean Air Act, I have experience working with a number of other federal environmental statutes. Some examples are listed below: