Angela Morrison is Board Certified in Federal and State Government and Administrative Practice and has been practicing environmental law for thirty years on behalf of utility and industry clients, assisting with legislative, regulatory, permitting, and compliance matters. Angela began her legal career at one of Florida’s leading environmental law firms in 1990, just as the Clean Air Act Amendments of 1990 were enacted. She quickly became an authority and played a large role in all of the major air-related rule-makings in Florida for the next decade. While she continues to be a leader in this niche area, Angela gained knowledge and experience in all of the various substantive areas of environmental law through her representation of utility clients and siting dozens of new units designed to generate several thousand megawatts of power. The scope of Angela’s practice has grown significantly over the years to include broader environmental representation on behalf of a wide variety of energy, communication, industry, manufacturing, developer, trade association, and government clients, including Fortune 100 and global manufacturing companies as well small entrepreneurial startups. In addition to the CAA, she has significant experience with wetlands, solid and hazardous waste, industrial wastewater, water quality, consumptive use, endangered species, and land use issues. She also has regulatory experience related to potential effects from large utility and industrial projects on traffic, cultural resources, local economies, vistas, odors, noise levels, and existing infrastructure.
As result of her rich experience in the complex field of environmental and land use law, at both the policy level and at the as-applied, practical level, Angela has authored a number of articles for legal and technical publications and has become a frequent speaker and lecturer. The Best Lawyers in America© has recognized Angela for the past three years in Environmental Law, Thomson Reuters selected her for Super Lawyers in 2019 and 2020, Florida Trend has recognized her as a Legal Elite, and she is AV rated by Martindale Hubbell.
Ms. Morrison received a B.A., summa cum laude, from Northeastern State University and a J.D. with High Distinction from Oklahoma City University School of Law where she was a Hatton W. Sumners Scholar, served as Managing Editor of the Law Review, and clerked as an intern for a federal district court judge and a state supreme court justice. She has been licensed to practice in Florida since 1990 and remains active with the Florida Bar’s Administrative Law Section and currently serves on the Executive Council for the Environmental and Land Use Law Section. Angela has also been very active with the American Bar Association’s Environment, Energy, and Resources Section, recently serving as a member of the Council. Angela is admitted to practice before the U.S. District Court for the Northern, Middle, and Southern Districts of Florida.
Over the past thirty years, Angela Morrison has assisted her utility, industry, and government clients with environmental-related legislation, rulemaking, permitting, variances, waivers, recordkeeping and reporting, compliance, enforcement, administrative litigation, appeals, and audits at federal, state, and local levels on a wide variety of matters. The scope of her environmental practice is broad, and the following list is reflective of her experience and the types of issues she has addressed and continues to address on behalf of her clients. Recently, Angela was co-lead counsel on the successful licensing of a large new power plant. Within the last few months, she also helped lead an industry effort that uncovered errors in data used to establish a federal air emission standard. Through the team's interactions with agency representatives, the client received relief in the form of an alternative standard at the state level, and the federal agency is currently in the process of revising its rules to make this alternative standard available nationwide.
- Air quality--Title V air operation permits, New Source Review permitting (PSD and Nonattainment NSR), state and federal emission standards (including NSPS and NESHAPs), Florida's State Implementation Plan, Florida's 111(d) Plans, CISWI, Risk Management Plans, federal and state ambient air quality standards, acid rain program, regional haze, air toxics, ozone and lead nonattainment programs, emissions trading programs, PSD increments, mobile source programs, BACT and RACT emission standards, air quality monitoring and modeling, fugitive sources, continuous monitoring requirements, minor source permitting, general air permits, de minimis emissions and permit exemptions, NSR enforcement initiative defense and responses to Section 114 information requests
- Climate change--sustainability, greenhouse gases, emission standards, cap and trade programs, emission reporting, federal carbon dioxide emission standards for utilities (Clean Power Plan), risk assessments, the Tailoring Rule and implementation of the PSD program for greenhouse gases
- Site certifications--environmental and land use approvals for generating and linear facilities, need for power determinations and Public Service Commission approvals, Florida Electrical Power Plant Siting Act, Transmission Line Siting Act, modifications, post-certification amendments
- Health risk assessments--single and multi-pathway, acute and chronic exposures, thresholds
- Due diligence--for asset purchases, appropriate inquiries, asset retirement, financial assurance
- Release reporting--hazardous substance reporting under federal programs such as EPCRA and CERCLA, continuous and permitted releases, State Warning Point, annual operating reports, inventories, and Florida's relatively new Pollution Incident Reporting Program
- Renewable energy--crops; incentives, grants, and loans; expedited permitting; ethanol and biodiesel manufacturing and distribution; Renewable Portfolio Standards; cap and trade programs
- Tax credits and exemptions--for renewable energy, manufacturing, and control equipment
- Water--consumptive use, industrial and thermal discharges, mixing zones, entrainment and impingement, impacts from air emission deposition, water quality standards for groundwater, surface, and drinking water
- Waste--alternative fuels, comfort letters, non-hazardous secondary material determinations, tires, storage, transportation, conversion and reuse, reduction goals, coal ash
- Wetlands--mitigation and mitigation banks, jurisdictional determinations, potential impacts
- Endangered species--listings, habitat, potential impacts, permits, mitigation, takings
- Agricultural-related approvals--energy crops, non-native species, biomass processing
- Local noise, odor, other nuisance ordinances--including special exceptions, variances
- Community outreach efforts and communications--including Environmental Justice concerns
With their broad reach, the Clean Air Act and other environmental laws have has impacted virtually all stationary sources in one way or the other over the years. This has given Angela an opportunity to represent an array of diverse clients and, in a growth state like Florida, provided a virtually unparalleled opportunity to be involved with an impressive variety of facilities being constructed, operated, expanded, modified, converted, or relocated, including some of the first large-scale biomass and alternative fuel projects to be permitted in the state.
To help keep her clients informed and to consider potential impacts on regulated industry, Angela has actively monitored Florida and federal legislative and regulatory actions related to air emissions, climate change, and stationary sources since she began practicing in 1990. She routinely assists clients with seeking improvements to state and federal rules to ensure that their interests are being appropriately considered, to help raise awareness of potential consequences, and to minimize unnecessary adverse economic impacts.
Angela represents her clients before the following agencies and tribunals:
- U.S. Environmental Protection Agency
- U.S. Department of Justice
- U.S. Army Corps of Engineers
- U.S. Fish and Wildlife Service
- Florida Department of Environmental Protection
- Florida Environmental Regulation Commission
- Florida Division of Administrative Hearings
- Florida’s Water Management Districts
- Florida Public Service Commission
- Florida Department of Agriculture and Consumer Services
- Florida Fish and Wildlife Conservation Commission
- Florida Department of Health
- Florida Department of Business and Professional Regulation
- Governor and Cabinet
- Florida Legislature
- Municipal governments and boards
Overview of the Title V Operating Permit Program, American Bar Association, The Clean Air Act Handbook, Chapter 15, 3rd edition (2011), 4th edition (2016).
“New Source Review Permitting,” Florida Environmental and Land Use Law 23.2.1, Treatise of The Florida Bar Environmental and Land Use Law Section (Co-Author, Chapter on New Source Review permitting) (2011).
Recent Publications- Periodicals
Title V Permit Renewals, American Bar Association Environment, Energy, and Resources Section, Trends (January/February 2015).
Air Emissions and NHSM Waste Determinations--Certain Uncertainty, American Bar Association Natural Resources & Environment, Vol. 28, No. 3 (2014).
New Federal Renewable Fuel Standard Program Rules and Potential Obstacles for Implementation, American Bar Association Natural Resources & Environment, Vol. 25, No. 4 (2011).
Improving Regulations for Biomass-Based Electrical Generating Facilities, American Bar Association Natural Resources & Environment, Vol. 23, No. 1 (2008).
Energy & Air Quality Policy and Regulatory Reform Under the New Trump Administration, Annual Environmental Permitting Summer School, Marco Island (July 2018).
Discovery of Contamination, Release Reporting, and Corrective Measures, Florida Section Air & Waste Management Association Annual Conference, Tallahassee (October 2017).
Energy & Air Quality Policy and Regulation Under the Trump Administration, Annual Environmental Permitting Summer School, Marco Island (July 2017).
Florida's New Pollution Reporting Rule: Do you know what you need to know?, Coastal Plains Chapter of the Air & Waste Management Association, Annual Technical Conference, Pensacola (June 2017).
Clearing the Smog: What you need to know about the new ozone standard, Coastal Plains Chapter of the Air & Waste Management Association, Annual Technical Conference (June 2016).
Penny Wise Pound Foolish: Good environmental practices will save your business time and dollars, Coastal Plains Chapter of the Air & Waste Management Association, Annual Technical Conference (June 2015).
EPA Regulation of Conventional Air Pollutants: What Will Keep Lawyers Busy, American Bar Association's Super Conference on Environmental Law, San Francisco (March 2015).
Hot Air Topics in Region 4, American Bar Association's Environment, Energy and Resources Section Conference, Key Environmental Issues in U.S. EPA, Region 4, Atlanta (March 2015)
Startup Shutdown Malfunction: Is Our Rule in Jeopardy?, Air & Waste Management Association Northeast Florida Chapter Conference (February 2015).
GHG Permitting Update: Sorting it all out, Annual Environmental Permitting Summer School (July 2014).
GHG and Climate Change Regulation Update, Interim Report: Earth, Wind, and Fires – Is the End Near?, Coastal Plains Chapter of the Air & Waste Management Association, Annual Technical Conference (June 2014).
Air Permitting for Greenhouse Gas Emissions, Annual Environmental Permitting Summer School (July 2013).
EPA’s New RICE Rules and What You Need to Know, Coastal Plains Chapter of the Air & Waste Management Association, Annual Technical Conference (June 2013).
PSD Applicability for Greenhouse Gas Emissions, National Energy, Utility & Environment Conference, Phoenix (January 2013).
Paradigm Shifting: Waste Materials Used for Recycling and Bioenergy Are Now Valuable Commodities, Air & Waste Management Association 105th International Conference, San Antonio (June 2012).