Mr. Samuel Brown

Sam’s practice focuses on federal and California-specific environmental and administrative law matters. He advises private and public sector clients from various sectors—electric utilities, general manufacturing, municipal utilities, land development, mining, food and beverage, among others—on all aspects of environmental law, including permitting, compliance counseling, administrative and civil enforcement defense, internal audits, transactional due diligence, and litigation.

Sam has extensive government experience from his prior role as an attorney in the US Environmental Protection Agency’s (EPA) Office of Regional Counsel in San Francisco (Region 9) and the Office of General Counsel in Washington, DC. 

Relevant Experience

Compliance Counseling, Permitting & Due Diligence. Sam counsels clients on maintaining compliance with a diverse range of regulatory programs. He has significant experience working directly with federal and state regulatory agencies. His compliance counseling and permitting experience includes navigating the Clean Water Act, the Safe Drinking Water Act, the Resource Conservation and Recovery Act, the Clean Air Act, the Toxic Substances Control Act, the National Environmental Policy Act, the Endangered Species Act, and state-equivalent environmental, health and safety, and consumer product-related statutes. His experience also includes counseling clients during real estate transactions and corporate mergers and acquisitions involving due diligence associated with necessary permitting requirements and potential environmental-related liabilities.

Enforcement Defense. Sam represents clients in government investigations, citizen suits, and administrative and civil enforcement actions associated with environmental statutes. His experience as a former US EPA enforcement attorney provides invaluable insight into how enforcement decisions are made, the process to resolve or litigate an enforcement action and the associated strategies and risks.
Administrative Law. Sam counsels clients on agency rulemaking, permitting or other actions, in particular those by EPA, the EPA regional offices and California regulatory agencies. He represents clients and associations in developing strategies for engaging agencies during the rulemaking process, reviewing and commenting on proposed rules and permits, and challenging final agency actions under environmental statutes and the federal and California Administrative Procedures Act.

U.S. Environmental Protection Agency. Prior to joining Hunton & Williams, Sam was an attorney at the EPA in the Office of Regional Counsel in San Francisco and the Office of General Counsel in Washington, DC. He worked on a range of issues, including developing technology-based effluent limitation guidelines for specific industrial sectors, drafting permits and defending those permits before the Environmental Appeals Board and in federal court, developing media-specific guidance, and advising the EPA Administrator and EPA General Counsel on the legal risks and defensibility of proposed regulatory actions. He developed significant substantive experience in the areas of water quality, wetlands, drinking water, and groundwater. He worked closely with state environmental agencies on the implementation and enforcement of delegated federal programs. He led investigations of regulated facilities for violations of environmental laws and pursued administrative and civil enforcement actions.

Public Speaking Experience. Sam speaks at events nationally on issues associated with environmental law, the enforcement of environmental laws, and understanding how EPA and the California environmental agencies operate. 

Sam is currently an adjunct professor at the University of San Francisco where he teaches environmental law. He is a former guest lecturer at Taras Shevchenko National University of Kyiv School of Law in Ukraine, where he taught on matters related to unconventional oil and natural gas development in Eastern Europe. He is also a former adjunct professor and guest lecturer at Pace University School of Law, Golden Gate University School of Law and The George Washington University School of Law where he taught environmental, energy and land use subject matter.