Christopher L. Bell

Christopher L. Bell

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Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes internal investigations, responding to grand jury investigations and agency information requests, and negotiating consent, probation, and debarment agreements. He is currently the EPA Independent Monitor overseeing the nation’s largest investor-owned energy company’s compliance with complex debarment and probation agreements arising from the resolution of criminal enforcement case brought under the Clean Water Act.

Chris assists buyers, sellers, investors and financial institutions on the environmental aspects of transactions, including conducting due diligence, negotiating the environmental provisions of transactional documents, and identifying and executing insurance-based risk management opportunities. His transactional experience has included upstream, midstream and downstream energy projects, alternative energy projects, and transactions in the manufacturing, logistics, consumer products and chemicals sectors.

He helps clients evaluate and implement compliance and ethics programs (e.g., under the Sentencing Guidelines), and environmental, health and safety management systems (including based on ISO 14001). Chris advises clients on sustainable development, climate change, product and chemical stewardship and regulation, and value chain management. He recently served on an independent committee advising the senior management of a Fortune 50 company on its global sustainability strategy and reporting.

He is also experienced with international matters, including compliance with product and chemical regulations in the EU and Asia, and the international transportation of raw materials and waste. For over twenty years he has represented industry in the development of international standards, including ISO standards on EMS (ISO 14001), auditing, life cycle assessment, sustainable development, nanotechnology, and anti-bribery management systems (ISO 37001).

Chris spent a year seconded to a major multinational corporation as in-house counsel, and has worked with clients in many sectors, including power generation and distribution, natural gas, alternative energy, transportation, chemicals, oil exploration and production, life sciences, natural resources, defense, electronics, communications, real estate, consumer products, retail sales, and general manufacturing.

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Capabilities

Experience

  • Defending a railroad in an EPA enforcement case arising from the derailment of a train transporting crude oil, as well as in related citizen suits brought under the Clean Water Act and the Oil Pollution Control Act.
  • Represented a manufacturing company in a criminal Clean Air Act investigation; the government declined to bring charges.°
  • Defended a railroad in a criminal Clean Water Act case arising from a release of chemicals; the court dismissed the charges on preemption grounds prior to trial.
  • Defending an energy company in a Clean Air Act enforcement case being brought regarding emissions from its upstream operations.
  • Represented a multiple-facility resolve combined criminal and civil enforcement claims under the Clean Air and Clean Water Acts, including negotiating probation and debarment agreements and advising the company on implementing and complying with those agreements.
  • Defended companies in Department of Energy enforcement actions involving allegations of violations of energy efficiency standards.
  • Defended power generation clients in Represented several power generating facilities in Clean Air Act new source review enforcement cases.°
  • Represented clients in numerous enforcement actions involving allegations of the improper use, storage and disposal of PCBs.
  • Defended a railroad in a toxic tort suit alleging damages from coal dust released from railcars; case dismissed on preemption grounds.
  • Defended companies facing allegations of violations of TSCA, including PMN and import/export requirements.°
  • Defended a chemical company in criminal and civil enforcement actions arising from chemical releases (including one leading to a fatality).°
  • EPA Independent Monitor overseeing Duke Energy’s compliance with a complex set of debarment and probation agreements arising from a guilty plea to violations of the Clean Water Act associated with releases of coal ash.
  • Assist facilities in applying for, obtaining, defending and complying with Clean Air Act and Clean Water Act permits.
  • Assisted dozens of companies around the world design, implement and evaluate environmental management and compliance systems, including systems based on ISO 14001 and the Sentencing Guidelines.
  • Advise clients on water rights in Texas, including negotiating various types of agreements involving the sale and use of water rights.
  • Served as member of independent peer-review committee reviewing and commenting on a Fortune 25 company’s global sustainability strategy, as well as its annual sustainability report.
  • Advise clients on compliance auditing programs, including disclosure under Federal and state auditing policies, conducting audits, and evaluating corporate auditing programs.
  • Provide compliance advice under all of the major environmental statutes, including the Clean Air Act, RCRA, Clean Water Act, TSCA (including PCBs and the balance of the chemical regulatory program, including PMNs, substantial risk reporting, etc.) and FIFRA.
  • Conducted a comprehensive environmental compliance systems review of a large multi-state natural gas pipeline and distribution system.
  • Advise clients on compliance with non-U.S. environmental requirements, including REACH, ROHS and international transportation requirements (e.g., Basel Convention, IMDG).
  • Represent clients in D.C. Circuit challenges to EPA rulemakings under RCRA, the Clean Air Act and TSCA. Recent representations include appellate litigation involving the Clean Power Plan, the RCRA Non-Hazardous Secondary Materials rule, the RCRA Subtitle D solid waste rules, the revised MACT standard for the plating and anodizing sector, and a petition to regulate lead-containing ammunition under TSCA.
  • Lead U.S. negotiator in the drafting of the original ISO 14001 EMS standard, as well as ISO standards on environmental auditing, life cycle assessment, and environmental performance evaluation.
  • Regularly write comments on proposed rules under the Clean Water Act, Clean Air Act, RCRA, TSCA and FIFRA.
  • Part of the U.S. international team negotiating ISO standards on nanotechnology since 2005, including serving as the primary drafter of ISO/TR 13121 Nanomaterial Risk Evaluation (2011) and the chair of ISO/TC 229’s task group on nanotechnology and sustainability.
  • Represented a trade association in negotiating with EPA a favorable regulatory interpretation encouraging the beneficial re-use of recovered materials.
  • Member of the U.S. negotiating team for the recently published ISO 37001 standard on anti-corruption management systems. 
  • Represented a petro-chemical company in a remedial and natural resources damages matter involving a wetlands/riverine environment.°
  • Advising several clients on PCB remediation and decontamination matters, including dredging and soil remediation projects, managing the demolition and decommissioning of buildings, and the disposition of PCB containing or contaminated equipment.
  • Conduct environmental due diligence on transactions, including reviews of legacy environmental conditions, operational compliance, and environmental issues related to product portfolios.
  • Negotiate environmental provisions of transactional documents.
  • Represented clients in several transactions involving wind and solar projects.
  • Advise clients on risk management solutions such as insurance to address legacy environmental issues in transactions.
  • Help manage compliance challenges in the transactional context, including post-closing auditing and the applicability of Federal and state audit disclosure policies. 

°The above representations were handled by Mr. Bell prior to his joining Greenberg Traurig, LLP.

  • Certified Manufacturing Technician (Society of Manufacturing Engineers, 1979)

Recognition & Leadership

  • Listed, Chambers USA Guide, 2007-2017
  • Team Member, U.S. News - Best Lawyers®, Best Law Firms Edition, "Law Firm of the Year," Environmental Law, 2016
  • National Law Journal Energy and Environmental Trailblazer 2017
  • American National Standards Institute Meritorious Service Award (2015)
  • Member, Society of Manufacturing Engineers

Credentials

Education
  • J.D., magna cum laude, University of Michigan Law School, 1985
    • Order of the Coif
  • B.A., Michigan State University, 1981
Clerkships
  • Hon. Philip Pratt, U.S. District Court for the Eastern District of Michigan
Admissions
  • Texas
  • District of Columbia
  • U.S. Court of Appeals for the District of Columbia Circuit