Our Professionals

Biography

Paul C. Sarahan has more than 32 years of experience advising clients on complex environmental, infrastructure, utility, and transportation matters. His practice includes permitting, remediation, enforcement defense, environmental auditing, regulatory counseling, litigation, and transactional support.
Before returning to private practice in 2005, Paul served as Director of the Litigation Division at the Texas Commission on Environmental Quality (TCEQ). He now represents companies in the energy, chemical, manufacturing, waste disposal, transportation, ranching, and retail industries before federal, state, and local agencies.

Paul’s work spans a wide range of environmental legal issues, including:

  • Environmental permitting
  • Waste handling, disposal, and Superfund matters
  • Water rights and water quality
  • Air quality regulation
  • Administrative, civil, and criminal enforcement strategy and defense
  • Environmental auditing
  • Environmental due diligence and litigation
He is increasingly active on behalf of landowners and ranchers in matters involving development, infrastructure projects, and related environmental and regulatory issues.
Paul routinely appears before TCEQ, the U.S. Environmental Protection Agency, and has handled matters before environmental agencies in Louisiana, Mississippi, Florida, Georgia, and Wyoming. His regulatory practice also includes matters before the Public Utility Commission of Texas, Railroad Commission of Texas, the Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Coast Guard, U.S. Army Corps of Engineers, Federal Aviation Administration, and Federal Railroad Administration.
Paul received his undergraduate degree from the University of Texas at Austin, his J.D. from the University of Texas School of Law, and his LL.M. in Environmental, Energy, and Natural Resources Law from the University of Houston Law Center.
Outside of his legal practice, Paul is active in community initiatives focused on economic development, transportation, and racial reconciliation. He enjoys using his smoker as often as possible, particularly for curing and smoking his own Spicy Bourbon and Maple Syrup Bacon. Paul is a member of the State Bar of Texas and its Environmental & Natural Resources Law Section, where he serves as Vice-Chair, as well as the Administrative & Public Law Section. He is also a member of the Texas Wildlife Association and the Texas and Southwestern Cattle Raisers Association.

HONORS & AWARDS

Ranked: Chambers USA, Environment – Texas, 2017, 2019-present
Best Lawyers in America, Environmental Law, 2016, 2018-present
Litigation–Environmental, 2016, 2018-present

Texas Super Lawyers, Environmental Law, 2014-2019
The Legal 500 USA, Energy: Regulatory, 2015

REPRESENTATIVE MATTERS

Environmental Regulatory Strategy, Permitting & Compliance

  • Represents companies in municipal solid waste (MSW), industrial, and hazardous waste (IHW), and underground injection control matters
  • Advises manufacturing facilities on air, water, and waste compliance and permitting requirements
  • Advises companies on carbon sequestration regulatory frameworks and permitting issues before the EPA and state environmental agencies
  • Advises companies on environmental audits; air, water, and waste compliance; regulatory interpretations; and transportation-related regulatory issues involving PHMSA and the Texas Railroad Commission
  • Represents companies in proceedings before groundwater conservation districts

Environmental Litigation

  • Represents ranchers and landowners in oil spill disputes, waste remediation matters, and related litigation
  • Represents ranchers and landowners in contested case permitting hearings before the TCEQ, the Railroad Commission of Texas, and the State Office of Administrative Hearings
  • Successfully defended a concrete company against criminal allegations involving unauthorized discharges to water
  • Represented a chemical company in a criminal investigation, resulting in avoidance of all criminal charges and dismissal of accompanying civil and administrative actions
  • Served as a subject matter witness on environmental compliance history issues

Infrastructure, Utility & Transportation

  • Represents ranchers and landowners in transmission line proceedings before the Public Utility Commission of Texas
  • Represents landowners in permitting and regulatory matters before the Railroad Commission of Texas
  • Represents transportation companies before the Texas Department of Motor Vehicles
  • Represents interstate pipeline companies in regulatory and enforcement matters before PHMSA

Remediation, Brownfields & Site Redevelopment

  • Handles brownfields, Superfund, voluntary cleanup, innocent landowner, and dry cleaner remediation matters for corporate clients
  • Helps companies demonstrate eligibility for brownfields tax credits

Environmental Markets & Strategic Advisory

  • Represents companies in TCEQ grant matters under the Texas Emissions Reduction Plan
  • Advises landowners in water rights transactions
  • Serves as general counsel to a water supply corporation

Incident Response & Crisis Management

  • Provides guidance to companies before and after natural disasters
  • Represented a shipping company in addressing environmental issues with the U.S. Coast Guard and TCEQ following a maritime accident
  • Represented a petrochemical facility in emergency response efforts involving multi-agency investigations and enforcement actions

Government & Legislative Affairs

  • Represents clients on matters involving the Texas Public Information Act, including requests, requirements, and applicable exceptions
  • Advises clients on legislative advocacy initiatives

Transactions & Environmental Due Diligence

  • Assists buyers, sellers, and lenders in evaluating environmental risks, assessing potential liabilities, and developing solutions that enable transactions to close