Shannon focuses on three primary areas: government and regulatory affairs, compliance counseling and enforcement defense, and environmental litigation. Shannon S. Broome is the managing partner of the firm’s San Francisco office and also maintains an office in Washington. Splitting her time between the San Francisco and Washington offices allows her to serve clients nationally, and with a focus on California, a jurisdiction frequently at the forefront of environmental regulation.
She counsels, advocates, and represents clients on a range of environmental statutes before state and federal courts and administrative agencies. Her practice has a particular emphasis on the Clean Air Act and corresponding state and local statutes and regulations. She advocates on regulations issued by and before numerous federal and state regulatory agencies.
Shannon’s practice also focuses on implementation of related statutes, including on the federal side the Energy Policy Act of 2005, the Energy Independence and Security Act of 2007, the Occupational Safety and Health Act, and the Environmental Policy and Community Right-to-Know Act. In California, she also routinely advises clients on state and local regulations as well as on implementation of the California Global Warming Solutions Act (AB32), California’s Low Carbon Fuel Standard and the California Environmental Quality Act.
Involved in development of virtually every major regulation issued following enactment of the Clean Air Act Amendments of 1990, Shannon used her multifaceted experience to provide clients advice on compliance and enforcement actions. Shannon was deeply involved, on behalf of clients, in the development of EPA’s Risk Management Program (RMP) regulations, which were issued under the Clean Air Act Amendments of 1990; and also involved the simultaneously enacted Process Safety Management (PSM) program regulations by the Occupational Safety & Health Administration.
From 1994 to 2000, Shannon was counsel and manager of Clean Air Act programs for the General Electric Company, where she was responsible for CAA advocacy, compliance and training for more than 200 manufacturing facilities, including RMP program advocacy and compliance. Previously, she was an environmental and construction engineer for Chevron, USA.
In her work as counsel for GE, Shannon achieved numerous regulatory changes in the RMP rules between proposal and promulgation and subsequently challenged EPA’s regulations, resulting in a successful settlement. She was a lead counsel advising on implementation of RMP at General Electric (which at the time included GE Plastics) and was part of the team that achieved a record number of voluntary protection program (VPP) designations for the company. She participated in management reviews of implementation of these requirements and was the lead liaison to GE Aircraft Engines on these issues during her tenure at the company. Shannon also has advised companies on compliance obligations under the General Duty Clause, RMP and compliance certifications for the same.
Shannon is a nationally recognized authority on Clean Air Act matters, with more than 25 years of experience addressing all aspects of the act, representing clients in a variety of manufacturing and energy sectors, including automotive, aerospace, pharmaceutical, chemical, paper, alternative fuels, power generation and utilities. Chambers USA describes Shannon as “a veritable Clean Air Act encyclopedia,” stating that “her strong technical engineering background has been an invaluable asset” and noting that her “record of success speaks for itself.”
Shannon’s litigation practice is primarily focused on challenging and defending EPA and California regulations and permits before federal and state appellate courts. She has litigated many environmental permit appeals before environmental hearing boards in various states. Shannon also is deeply knowledgeable on environmental enforcement matters.
Shannon’s clients describe her as an “outstanding lawyer – very practical, effective, extremely smart and incredibly knowledgeable” (Chambers USA).
From 1992 through 2000, Shannon was a vital participant in many EPA stakeholder discussion roundtables on New Source Review as EPA’s reform process for those regulations proceeded. In June 2004, Shannon was selected by EPA to serve as one of six industry representatives and one of 18 outside members of the Title V Task Force under the Permits, New Source Review and Toxics Subcommittee of the Clean Air Act Advisory Committee, a group charged with evaluating the state of the Clean Air Act’s Title V permitting program and making recommendations for improvement. In 2009, she participated on EPA’s Greenhouse Gas BACT Workgroup, a subgroup of EPA’s Clean Air Act Advisory Committee, which addressed the potential application of controls for greenhouse gases under the act. In that role, she was involved in the development of two reports to EPA that were used as a framework to develop its November 2010 PSD and Title V Permitting Guidance for Greenhouse Gases.
Shannon is admitted in the Supreme Court of California; US District Court, Eastern District of California; and US Court of Appeals for the District of Columbia, Ninth and Tenth Circuits.
