Counsel Paul Sarahan focuses on advising clients on environmental and workplace safety issues related to business transactions, enforcement, auditing, litigation, permitting, tax incentives and nanotechnology. He advises clients on property tax issues that involve the Texas pollution control exemption and other environmental issues. In addition, Paul advises clients on legislative activities.
Prior to joining the firm in 2005, Paul was the Director of the Litigation Division of the Texas Commission on Environmental Quality ("TCEQ") for seven years with four years of prior experience as a Senior Attorney and Staff Attorney. While at the TCEQ, Paul was rated one of the top in-house counsel by the Texas Lawyer. While at TCEQ, Paul litigated complex enforcement matters and handled compliance history, penalty policy, and emission event issues. He advised TCEQ's Environmental Audit, Superfund, and PST programs, and reviewed criminal cases brought by the state's environmental crimes task force.
Paul's recent significant projects include:
- Advised various pipeline operations on TCEQ enforcement matters, including investigations related to operations in the Barnett Shale; air permitting matters; emissions inventory issues; greenhouse gas reporting requirements; and Department of Transportation registration requirements
- Represented clients in administrative enforcement actions brought by the Texas Commission on Environmental Quality and the Environmental Protection Agency
- Advised midstream oil and gas operations regarding various air issues, including Title V compliance, emission event reporting requirements, authorization under a standard permit, and greenhouse gas reporting requirements
- Assisted clients in developing and implementing environmental audit programs
- Advised clients on Occupational Safety and Health Administration (OSHA) requirements
- Represented a power plant in obtaining a reversal of a negative use determination on an application for an environmental tax exemption
- Represented clients in Superfund matters
- The College of the State Bar of Texas
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State Bar of Texas
- Environmental Law Section
- Administrative Law Section
- Air & Waste Management Association, Central Texas Chapter, Vice-Chair
- "Top Ten Experts in Environmental, Health, and Safety Issues Related to Engineered Nanomaterials," Nanotechnology Law & Business, Vol. 6, No. 1, Spring 2009
- "The In-House Crowd," Texas Lawyer, November 2005
- "NIOSH Proposes Occupational Exposure Levels for Carbon Nanotubes and Nanofibers," Fulbright Briefing, January 12, 2011
- Co-author, "Targeting Nanoscale Materials Operations," Law 360, May 19, 2010
- Co-author, "Texas Power Plants Obtain TCEQ Ruling Supporting Pollution Control Property Tax Exemption for HRSGs," Fulbright Alert, December 7, 2012
- "TCEQ Adopts Compliance History Revisions," Fulbright Briefing, June 29, 2012
- Co-author, "Responding to NIOSH's Nanomaterial Exposure Limits," Law360, May 24, 2011
- "University Nano Labs: Assessing And Minimizing Environmental, Health, And Safety Risks," The Journal of College and University Law, National Association of College and the University Attorneys and the Notre Dame Law School, 2011
- Co-author, "TCEQ Revises Permit by Rule and Standard Permit Authorizations for Oil and Gas Facilities in the Barnett Shale," Fulbright Alert, January 27, 2011
- Co-author, "OSHA Publishes Final Regulations on Whistleblower Provisions under Energy Reorganization Act and Six Environmental Statutes," Fulbright Briefing, January 20, 2011
- Co-author, "EPA Proposes Expanded Greenhouse Gas Reporting Requirements," Fulbright Alert, April 13, 2010
- Co-author, "EPA Rejects Texas Air Pollution Permitting Rule; TCEQ Proposes Revised Rules," Fulbright Alert, April 1, 2010
- Co-author, "Texas Power Plants Obtain TCEQ Ruling Supporting Pollution Control Property Tax Exemption for HRSGs," Fulbright Alert, December 7, 2012
- "TCEQ Adopts Compliance History Revisions," Fulbright Briefing, June 29, 2012
- Co-author, "Responding to NIOSH's Nanomaterial Exposure Limits," Law360, May 24, 2011
- "University Nano Labs: Assessing And Minimizing Environmental, Health, And Safety Risks," The Journal of College and University Law, National Association of College and the University Attorneys and the Notre Dame Law School, 2011
- Co-author, "TCEQ Revises Permit by Rule and Standard Permit Authorizations for Oil and Gas Facilities in the Barnett Shale," Fulbright Alert, January 27, 2011
- Co-author, "OSHA Publishes Final Regulations on Whistleblower Provisions under Energy Reorganization Act and Six Environmental Statutes," Fulbright Briefing, January 20, 2011
- "NIOSH Proposes Occupational Exposure Levels for Carbon Nanotubes and Nanofibers," Fulbright Briefing, January 12, 2011
- Co-author, "Targeting Nanoscale Materials Operations," Law 360, May 19, 2010
- Co-author, "EPA Proposes Expanded Greenhouse Gas Reporting Requirements," Fulbright Alert, April 13, 2010
- Co-author, "EPA Rejects Texas Air Pollution Permitting Rule; TCEQ Proposes Revised Rules," Fulbright Alert, April 1, 2010
1993 - LL.M., Environmental, Energy and Natural Resources Law, The University of Houston Law School
1990 - J.D. with honors, The University of Texas School of Law
1987 - B.B.A., Finance, The University of Texas at Austin
He is admitted to practice in the United States District Courts for the Southern District of Texas, the Fifth Circuit Court of Appeals and the Texas Supreme Court.
College football, baseball, and traveling with his family
- Texas
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Healthcare for the Homeless - Houston
- Associate Board
- The University of Texas, Chancellor's Council
