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LeAnn Johnson Koch is a member of the Environment, Energy & Resources practice and has over 20 years of experience representing the petroleum refining industry, energy sector, and other industrial clients on environmental compliance matters, enforcement defense, rulemaking proceedings, permitting actions, transactions and emergencies.
LeAnn has substantial experience defending administrative, civil judicial and criminal enforcement of environmental laws and has represented numerous clients negotiating consent decrees under EPA's National Petroleum Refining Initiative. Another aspect of LeAnn's practice is responding to environmental emergencies, including oil spills, explosions and fires.
LeAnn regularly advises clients on compliance with complex technical regulatory obligations under the federal environmental statutes and their state counterparts with particular emphasis on Clean Air Act matters, including climate change, NSR/PSD, MACT, NESHAP and NSPS. On behalf of her clients, she tracks and reports on agency rulemakings, policy interpretations and enforcement initiatives and represents clients challenging federal and state rulemaking proceedings. She counsels clients on a variety of compliance issues, from quick answers about regulatory applicability to sophisticated issues involving ambiguous regulatory requirements.
LeAnn also counsels clients on fuels issues, including the renewable fuel standard, low sulfur gasoline, low sulfur diesel, and exhaust toxics. On fuels issues, LeAnn assists clients in rulemaking proceedings commenting on and appealing agency rulemakings as well as counseling clients on compliance, and petitioning for waivers or relief from fuels standards.
LeAnn has extensive experience on big and small air permitting matters, from reviewing draft permit applications and annual compliance certifications to initiating and defending permitting appeals involving cutting-edge issues including NSR/PSD, flaring, climate change, impacts on endangered species and innovative technologies.
She also routinely counsels clients on the environmental aspects of transactions, including purchasing, selling and leasing industrial facilities. She has negotiated purchase and sale and lease agreements for a multitude of clients, from major industrial complexes to gas station portfolios. LeAnn has conducted environmental due diligence, qualified sites under state Brownfields programs and negotiated cleanup programs and financial assurance with EPA and state agencies.
LeAnn's air practice also includes mobile source counseling, including enforcement defense related to engine certification and EPA regulation of tailpipe emissions. LeAnn represents manufacturers, vendors and retailers of vehicles and engines manufactured overseas and imported into the United States.
