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Patrick D. Traylor
Partner, Washington, D.C.
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Patrick Traylor practices in the area of environmental law, with a particular focus on the Clean Air Act, environmental litigation, and energy infrastructure development and climate change.

Clean Air Act permitting, compliance, and litigation. Our clients rely on Patrick for their most demanding Clean Air Act permitting, compliance, and litigation challenges. From developing and executing sophisticated permitting strategies for the most complex air pollution sources to defending our clients against determined challenges by regulatory agencies and environmental groups, Patrick’s air practice is marked by a resourceful ability to reconcile complex environmental, technical, and economic requirements with our clients’ business objectives.

Environmental litigation. Patrick is an experienced litigator, representing clients before federal courts and administrative bodies. Environmental programs under which most frequently litigates include the Clean Air Act and the Endangered Species Act. His litigation practice is distinguished not only by a robust pursuit of business objective-driven offensive and defensive litigation, but also by skill in fashioning negotiated settlements where litigation risks prove economically unattractive.

Energy infrastructure development and climate change. Patrick’s practice is devoted largely to assisting clients navigate the environmental aspects of energy infrastructure development and operation. He has extensive environmental experience in the permitting and construction of new coal, gas, and renewable electric power generation, and served on the Department of the Interior’s Wind Turbine Guidelines Federal Advisory Committee. Because of this work in the energy sector, Patrick has extensive experience in the field of climate change law, including domestic and international policy development, permitting, strategic planning for carbon-intensive industries, and carbon trading.

Some of Patrick’s prominent clients include AES Corporation, The Anschutz Corporation, BHP Billiton, Chrysler Corporation, Duke Energy, Edison Mission Energy, Exelon, Flint Hills Resources, INVISTA, Leucadia, MidAmerican Energy, Minnkota Power Cooperative, PSEG, and Sithe Global.

  • As counsel for manufacturing, refining, clean energy, coal gasification, and biomass companies, Patrick has advised clients on developing and securing construction permits under EPA’s emerging greenhouse gas permitting rules as well as older new source review permitting rules.
  • As counsel for a Global 500 company, Patrick developed and implemented an air permitting strategy that facilitated the shutdown of a legacy manufacturing facility and its replacement with a state-of-the-art manufacturing facility.
  • As counsel for numerous international and domestic energy companies, Patrick has counseled clients on the development of over 8,000 MW of coal-fired, gas-fired, bio-mass fired, and wind energy projects under the Clean Air Act, the Endangered Species Act, the Bald and Golden Eagle Protection Act, the Migratory Bird Treaty Act, and the National Environmental Policy Act.
  • As counsel for several large utility companies, Patrick managed the administrative, litigation, and settlement elements of the Environmental Protection Agency’s New Source Review enforcement actions and related citizen suit challenges.
  • As counsel for a Global 50 company, Patrick led the environmental review team that cleared a manufacturing facility through the Department of Energy to produce next generation transportation electric batteries.
  • As counsel for a Global 500 company, Patrick leads Hogan Lovells team that responds to climate change-based citizen suits, engages with entrenched ENGO opponents of expanded operations, and integrates complex, multi-facility permitting strategies across numerous federal, tribal, and state regulatory authorities.
  • As counsel for a large Eastern U.S. utility company, Patrick managed the environmental components of more than $2 billion in equity and asset transactions, and has developed strategic environmental approaches to restructure merchant energy facilities.

    Hogan Lovells Publications
    08 December 2014 "How Will the EPA's New Ozone Air Quality Standard Affect the Permitting of New Facilities?" Environment Alert, Hogan Lovells

    01 May 2013 "EPA comments on the April 2013 Keystone NEPA review—monetizing the social costs of carbon dioxide emissions." Environment Alert, Hogan Lovells

    28 June 2012 "D.C. Circuit has upheld EPA’s greenhouse gas rules." Environment Alert, Hogan Lovells

    10 January 2012 "Environment Practice Secures Important Victory for Minnkota Power Cooperative." Environmental Alert, Hogan Lovells

    10 January 2012 "Patrick Traylor serves as panelist at environmental forum." Environmental Alert, Hogan Lovells

    May 2010 "Climate Change Newsletter." Climate Change Newsletter, Hogan Lovells

    29 April 2010 "SEC Guidance on Climate Change Disclosures Emphasizes Need for Early Warnings." SEC Update, Hogan & Hartson LLP

    06 March 2009 "Stimulus Legislation Update: Issue 4 - New Online Resources for Tracking Stimulus Funds." Stimulus Legislation Update, Hogan & Hartson LLP

    18 February 2009 "Stimulus Legislation Update: Issue 3." Stimulus Legislation Update, Hogan & Hartson LLP

    11 February 2009 "Stimulus Legislation Update: Issue 2." Stimulus Legislation Update, Hogan & Hartson LLP

    10 February 2009 "Stimulus Legislation Update: Issue 1." Stimulus Legislation Update, Hogan & Hartson LLP

    05 August 2008 "EPA/DOJ Enforcement Policies: Privilege, Parallel Proceedings, Post-Booker Sentencing, and Enforcement Priorities." Environmental Update, Hogan & Hartson LLP

    17 July 2008 "EPA Enforcement of CFC Refrigerant Rules Yields a $3.8 million Settlement Against Bristol-Myers Squibb." Environmental Update, Hogan & Hartson LLP

    16 July 2007 "Overview of International and Domestic Climate Change Programs and Initiatives." Focus On Climate and Clean Energy, Hogan & Hartson LLP

    23 May 2006 "EPA Announces Clean Air Act Enforcement Priorities for 2006-2007." Environment Update, Hogan & Hartson LLP

    21 March 2006 "New Source Review Inoculation—Environmental Risk Management After New York v. EPA." Environmental Update, Hogan & Hartson LLP

    16 December 2005 "DOJ Environmental Crimes Enforcement Secures Multi-million Dollar Fines and Sets Sights on New Prosecutorial Initiatives." Environmental Update, Hogan & Hartson LLP

    01 March 2005 "New Source Review Inoculation – Environmental Risk Management in the Face of Regulatory Uncertainty." Environment Focus On, Hogan & Hartson LLP

    16 February 2005 "Kyoto Protocol Enters Into Force February 16, 2005." Environment and Energy - Climate Change Update, Hogan & Hartson LLP

    01 August 2004 "Stratospheric Ozone Enforcement Program Yields Multi-million Dollar Fines." Environmental Update, Hogan & Hartson LLP

    25 May 2004 "EPA Announces Enforcement Initiative Against Hospitals." Environmental Update, Hogan & Hartson LLP

    Published Works
    28 May 2014 "Methane Regulation: It’s Not Just for Cows." Oil & Gas Monitor, www.oilgasmonitor.com/

    29 June 2011 "Energy Coal Policy in the 112th Congress: Objectives, Tools, and Compromises." American Coal, American Coal Council, Issue 1, 2011

    26 July 2010 "Tailpipes and Smokestacks: The Impact of Climate Change Policies on Mobile and Stationary Sources of Greenhouse Gases." The Legal Impact of Climate Change, Leading Lawyers on Navigating New Laws, Avoiding Liability, And Anticipating Future Challenges for Clients, 2010 Edition, Aspatore Books

    July/August 2008 "An Allowance to Take to the Bank." Environmental Finance

    July-August 2007 "What the US Can Learn From the CDM." Environmental Finance

    01 January 1999 "Explaining the Controversy Surrounding United States v. Smithfield Foods, Inc." William & Mary Environmental Law & Policy Review

    01 February 1998 "Presumptive MACT as a Regulatory Tool to Streamline the Development of National Emission Standards for Hazardous Air Pollutants." Environmental Lawyer

    Climate Change
    Litigation and Arbitration
    Infrastructure, Energy, Resources and Projects
    Legislation and Political Law Compliance
    Administrative and Public Law
    Environmental Litigation
    Energy and Natural Resources Group
    Renewable Energy
    • Clean Air Act permitting, compliance, and litigation
    • Environmental Litigation
    • Energy infrastructure development and climate change
    LL.M., The George Washington University Law School, 1998 J.D., South Texas College of Law, 1994 B.A., Texas A&M University, 1991
    • Member, Wind Turbine Guidelines Advisory Committee, U.S. Department of the Interior
    • Member, Boot Camp Steering Committee, Environmental Law Institute  
    • Member, Spring Conference Steering Committee, Environmental Markets Association, 2008
    • Chambers USA, District of Columbia, Environment (Up and Coming), 2014
    • Washington, D.C. Super Lawyers, Environmental, Energy & Natural Resources, Environmental Litigation, 2014-2015
    BAR ADMISSIONS / QUALIFICATIONS District of Columbia Texas
    COURT ADMISSIONS U.S. Court of Appeals, District of Columbia Circuit U.S. Court of Appeals, Tenth Circuit U.S. District Court, District of Columbia U.S. Court of International Trade U.S. District Court, District of North Dakota U.S. District Court, District of Colorado