CHRISTOPHER B. AMANDES
PARTNER
[email protected]
Houston
Phone +1.713.890.5735
Fax +1.713.890.4001
1000 Louisiana St., Suite 4000 \\ Houston, TX 77002-5006 \\ United States
Christopher B. Amandes focuses his practice on environmental law, with an emphasis on
environmental issues in transactions, regulatory compliance counseling, enforcement defense,
and dispute resolution. He works at the federal level with issues involving the US Environmental
Protection Agency (EPA) and at the state level with matters before the Texas Commission on
Environmental Quality (TCEQ). Chris handles a wide range of environmental regulatory issues,
including air, solid and hazardous waste, and water quality.
With a master’s degree in environmental engineering, Chris advises clients on compliance
counseling and enforcement defense for matters under the Clean Air Act (CAA), the Clean Water
Act (CWA), the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), the Toxic Substances Control Act (TSCA), and the Resource Conservation and
Recovery Act (RCRA).
Working with clients in industries including petrochemical, refining, power generation,
manufacturing, natural resources, and real estate, Chris advises on regulatory requirements
affecting their operations and helps identify cost-effective compliance solutions. These include
demonstrating compliance, negotiating penalty reductions and appropriate corrective action
requirements, performing self-audits, and developing supplemental environmental projects.
In transaction-related environmental matters, he negotiates environmental risk allocations, drafts
contract provisions to address environmental issues, and evaluates issues that may affect the
value or viability of a deal. He also represents asset sellers and buyers in bankruptcy proceedings.
Chris performs internal investigations of alleged environmental misconduct and represents
individuals and corporations in criminal environmental prosecutions.
His work has been recognized with a listing in the International Who's Who of Business Lawyers.
He is also ranked in the top tiers of environmental lawyers in Texas by Chambers USA and has
been listed in Best Lawyers in America since 1994.
SELECTED REPRESENTATIONS
Air Issues
Defended a Houston-area refinery in an enforcement case alleging excessive benzene emissions.
Obtained the first "single property order" from the Texas Commission on Environmental Quality (TCEQ),
allowing a number of "guest" units at a large integrated chemical manufacturing facility to obtain air
permits, using the facility's outer perimeter to demonstrate compliance with air quality requirements.
Negotiated an agreement for a Houston-area refinery to resolve alleged violations of Subpart J
requirements for flares via a multiyear corrective action program.
Negotiated and prepared agreements to accomplish numerous purchases and sales of air emission
reduction credits in the Houston-Galveston area.
Represented a chemical manufacturing facility in obtaining a revised permit for major source levels of
"newly discovered" volatile organic compound emissions without the need for installing air emission
controls.
Structured and persuaded the TCEQ to include a unique air permit provision protecting a lender's
interest in a structured financing of a new coker unit at a Texas refinery.
Assisted a Houston-area hazardous waste industrial furnace to obtain a determination that it was not
subject to stringent nitrogen oxide control requirements under the revised ozone state implementation
plan.
Resolved a TCEQ enforcement action against a Beaumont, Texas-area chemical manufacturing facility,
alleging that measured off-site concentrations of 1,3-butadiene constituted a condition of "air
pollution," with an agreement to conduct fenceline monitoring and perform appropriate response
actions without an assessment of penalties.
Solid and Hazardous Waste/Superfund Issues
Represented the purchaser in the first-ever agreement by a nonliable party to purchase from a
bankruptcy estate, clean up, and redevelop a National Priorities List Superfund site.
Advised the owner of a closed Beaumont, Texas-based refinery on minimizing the cost of numerous
hazardous waste closure obligations.
Negotiated the resolution of a major federal enforcement action alleging violations of the hazardous
waste regulations by a permitted incineration facility.
Participated as a key member of the team that negotiated a federal consent decree to address
remediation of polychlorinated biphenyl and natural gas condensate contamination under the Toxic
Substances Control Act and Resource Conservation and Recovery Act at approximately 60 sites in 14
states.
Represented the plaintiff in a CERCLA cost recovery claim that resulted in a substantial confidential
eight-figure settlement.
Served as common counsel to a potentially responsible party group at a state Superfund site in the
negotiation of remedial action and the defense of a toxic tort lawsuit.
Performed a privileged, detailed investigation of historic waste generation and disposal practices for a
Fortune 500 company for use in the allocation negotiations at a federal CERCLA site.
Helped numerous owners of contaminated properties obtain Texas voluntary cleanup program
certificates of completion and "innocent owner" certificates.
Helped a Houston-area industrial furnace minimize its trial burn requirements under a newly issued
boiler and industrial furnace permit.
Water Issues
Successfully resolved a federal wastewater enforcement action against a large Texas municipality and
avoided a proposed seven-figure penalty by negotiating a consent decree involving the performance of a
multiyear supplemental environmental project.
Defended a TCEQ-contested case enforcement action alleging multiple violations of a wastewater
permit, resulting in the agency's withdrawal of all allegations.
Represented a major oil and gas company in two separate Environmental Protection Agency Region 6
enforcement actions alleging violations of wastewater discharge limitations at offshore oil and gas
production platforms, each of which was resolved with agreed orders that included commitments by the
company to undertake specific operational and training improvements.
Represented a Houston manufacturing facility in a TCEQ enforcement action alleging unauthorized
discharges of a combined wastewater/stormwater stream that was resolved with an agreement that
included one of the first state supplemental environmental projects in exchange for a reduced penalty.
Criminal Issues
Represented an energy company in an internal investigation of alleged alteration of air emission
monitoring data and coordinated self-reporting under state and federal audit policies and subsequent
negotiation with regulatory agencies, which resulted in no criminal prosecution of the client.
Served as environmental counsel to an architectural coating company in a four-count state air pollution
criminal prosecution, which culminated in a not-guilty verdict on all counts.
Represented an energy company in two internal investigations of alleged environmental crimes
involving air, wastewater, and solid waste issues and coordinated self-reporting to state and federal
agencies and subsequent resolutions of the violations as civil matters.
AWARDS AND AFFILIATIONS
Ranked, Chambers USA: America's Leading Lawyers for Business (2003–2017)
Noted in The US Legal 500 for Environment: Litigation (2014)
Listed, The Best Lawyers in America (1994–2017)
Listed, Texas Super Lawyers (2003–2014)
Listed, International Who's Who of Business Lawyers (2008–2009, 2011)
Listed, Best of the Best USA in Environmental Law, Euromoney's Guide to the World's Leading Lawyers
(2008–2009)
Listed, Who's Who Legal (2007–2008, 2016)
Listed, Legal Media Group's Guide to the US, Best of the Best (2006)
Member of the Law360 Environmental Editorial Board
Former Member, City of Houston Planning Commission
Former First Chair, City of Houston's Brownfield Redevelopment Committee
Judicial clerk for the late Judge John R. Brown, US Court of Appeals for the Fifth Circuit (1985–86)
Chief Article Editor, UCLA Law Review
ADMISSIONS
Texas
CLERKSHIPS
Clerkship to Judge John R. Brown of the US Court of Appeals for the Fifth Circuit (1985 - 1986)
EDUCATION
University of California, Los Angeles School of Law, 1985, J.D.
Rice University, 1976, B.A.
Rice University, 1978, M. Environmental Engineering
SECTORS
Energy
SERVICES
Environmental Counseling & Litigation
Energy Transactions
Real Estate
REGIONS
North America