Andrew R. Stewart

ANDREW STEWART is a partner in the firm’s Environmental, Health, and Safety practice, which has a Chambers USA 2024 Band 1 ranking in the District of Columbia and was named a “Practice Group of the Year” by Law360 in the Environmental category. Andrew is recognized by Chambers USA for Environment in District of Columbia (2024–2025), and clients interviewed for the 2024 edition commented: 

“He’s a great lawyer who’s very timely and always provides excellent service on complex regulatory rules” and an “absolute professional with tremendous expertise in EHS law, and he dedicates his time to providing top-tier legal assistance.” 
Chambers USA 2024

Andrew is also listed among the 2025 Lawdragon “Green 500: Leaders in Environmental Law.” 

He is a former senior official from the U.S. Environmental Protection Agency (EPA), who helps clients solve a broad range of compliance and enforcement issues. Andrew focuses his practice on complex, high-stakes environmental matters, where an insider’s knowledge of the regulatory process is particularly important. These representations include enforcement matters, involving the EPA, state agencies, and the Department of Justice that arise under multiple environmental laws.

With more than 25 years of experience in Environmental law, he handles matters arising under all major federal environmental laws, as well as state laws, including the Clean Water Act (CWA), Clean Air Act (CAA), the Resource Conservation and Recovery Act (RCRA), and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). His work includes assisting clients in the retail, technology, oil and gas, chemical manufacturing, and life sciences, industries on permitting requirements, counseling on critical environmental obligations, and defense of government enforcement and citizen suit actions. Andrew counsels clients on addressing site impacts under federal environmental laws and permits, as well as reporting and other obligations under RCRA, the Comprehensive Environmental, Response, Compensation, and Liability Act (CERCLA), and the Emergency Planning and Community Right-to-Know Act (EPCRA) (including the Toxics Release Inventory). He regularly advises companies on making voluntary disclosures under both the U.S. EPA Audit Policy and state voluntary disclosure programs.

Andrew draws on his experience as a senior manager at the EPA, where he served as an acting division director in the Office of Civil Enforcement. During his tenure at the EPA, Andrew led various complex enforcement matters and litigation affecting numerous industrial sectors, including retail, oil and gas, chemical manufacturing, agribusiness, and mining. He handled cases relating to the CWA, CAA, RCRA, and FIFRA, among others. He also had lead responsibility for overseeing implementation of the EPA’s Audit Policy and resolution of numerous disclosures under the Policy. His service at the EPA also included work as a senior attorney in the Water Enforcement Division, handling enforcement matters related to the National Pollutant Discharge Elimination System and Spill Prevention, Control, and Countermeasure program requirements, as well as matters involving noncompliance with the wetlands program.

Andrew serves as vice-chair of the Enforcement and Litigation and Pesticides and Chemical Committees within the American Bar Association Section of Environment, Energy, and Resources.

A sampling of Andrew’s matters include:

• AI issues across a range of scenarios:
  
  • Counsel retail and technology clients regarding laws and programs applicable to generative AI applications.
  • Advise technology and developer clients regarding AI data center projects.
  • Counsel on regulatory requirements applicable to agentic AI tools.
  • Integrate AI tools in matters for technology and retail clients to capture enhanced efficiencies and streamline workflows.
• Retail, technology, life sciences, and manufacturing sectors:
  
  • Negotiate consent decrees and administrative settlements resolving claims under multiple statutes with DOJ and EPA.
  • Counsel clients on EPA’s PFAS reporting regulation under the Toxic Substances Control Act (TSCA) and on state PFAS programs.
  • Provide guidance to life sciences client on managing site impacts from PFAS.
  • Negotiate settlement of EPA claims on behalf of chemical manufacturing client under TSCA for import and use of TSCA regulated chemicals
  • Advise clients regarding registration, distribution, labeling, and import requirements under FIFRA and analogous state laws.
  • Represent companies in EPA enforcement investigations related to distribution and sale of pesticide products, including defense of FIFRA information requests and Stop, Sale, Use, or Removal Orders.
  • Counsel clients regarding TSCA, state chemical regulation requirements, and tort actions in relation to consumer products.
  • Counsel companies as to strategies for developing commercialization strategy for regulated pesticide products and obtaining federal and state registrations.
  • Negotiate resolution of EPA enforcement actions under FIFRA related to alleged sale of unregistered pesticide and labeling issues (misbranding).
  • Represent clients in EPA enforcement investigations related to importation of regulated pesticides and pesticide establishment requirements.
  • Represent client in California Department of Pesticide Regulation investigation.
  • Advise clients on applicability of pesticide law requirements to e-commerce transactions.
  • Conduct environmental due diligence for transactions involving products and activities to federal and state pesticide law.
  • Advise mining client on applicability of TSCA with respect to importation and use of chemical substances as well as follow-on enforcement matter.

• Energy sector representations arising under multiple environmental laws:
  • Negotiate administrative and civil judicial (consent decree) settlements with EPA and state environmental agencies.
  • Represent refining company in response to CAA information request and investigation related to CAA National Emission Standards for Hazardous Air Pollutants (NESHAPs). Subpart CC, Leak Detection and Repair, flaring, and Risk Management Plan programs.
  • Represent oil recycling company in Department of Justice enforcement action and litigation arising under RCRA.
  • Advise refineries regarding legacy site impacts and obligations under RCRA, CERCLA, and the CWA.
  • Develop and implement site investigation and remediation plans working with technical consultants.
  • Advise refining sector clients on requirements under CAA NESHAPs Subpart CC fence line monitoring program.
  • Counsel refining clients on reporting and cleanup obligations from releases under CERCLA and EPCRA.
  • Assist upstream client concerning reporting obligations under CERCLA and EPCRA.
  • Advise midstream and downstream clients on obligations under the Oil Pollution Act.
  • Represent midstream client in EPA enforcement matter arising under CAA related to fuel tank requirements.
  • Represent midstream client in connection with citizen suit proceeding under the CWA and RCRA.
  • Advise utility client on environmental auditing programs for CAA compliance.
  • Advise refinery clients on permit compliance issues related to New Source Review/Prevention of Significant Deterioration and Title V programs.
  • Conduct environmental due diligence in oil and gas sector transactions.

• Vice-Chair, ABA Pesticides and Chemicals Committee (2025–present)
• Vice-Chair, ABA Enforcement and Litigation Committee (2023–present)
• Co-chair, ABA Environmental Enforcement and Crimes Committee (2021–2023)
• Vice Chair, ABA Environmental Enforcement and Crimes Committee (2016–2021)
• Member, ABA Section of Environment, Energy and Resources Fall Conference Planning Committee (2021)