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.
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.
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.
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.
University of California, Los Angeles School of Law, 1985, J.D.
Rice University, 1978, M. Environmental Engineering
Rice University, 1976, B.A.
Clerkship to Judge John R. Brown of the US Court of Appeals for the Fifth Circuit (1985 - 1986)
Awards and Affiliations
Member, Law Firm of the Year, Energy/Projects: Power (including Renewables), Chambers USA (2018)
Member, Practice Group of the Year, Environmental, Law360 (2017)
Member, Practice Group of the Year, Energy, Law360 (2016)
Member, Energy Law Firm of the Year, US News & World Report/Best Lawyers (2015)
Ranked, Environment, Texas, Chambers USA (2003–2018)
Recommended, Environmental: Litigation, The US Legal 500 (2014)
Recognized, The Best Lawyers in America (1994–2018)
Recognized, Texas Super Lawyers (2003–2014)
Recognized, International Who's Who of Business Lawyers (2008–2009, 2011)
Best of the Best USA, Environmental Law, Euromoney's Guide to the World's Leading Lawyers (2008–2009)
Recognized, Who's Who Legal (2007–2008, 2016)
Recognized, 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)