Brian Freeman focuses his practice on environmental compliance counseling, permitting, site remediation, and related litigation regarding federal and state regulatory programs. Areas of particular focus include air quality, climate change, petroleum management, and waste management/recycling. Brian has worked with a variety of clients, ranging from Fortune 100 conglomerates to individual entrepreneurs, and across a broad spectrum of industries, including aerospace, specialty chemicals, petroleum, electricity generation, composting and organics management. His experience includes a several-month assignment working in the legal department of a major industrial client, where he handled a full array of environmental, health, and safety matters.
Brian has experience across the breadth of federal and state air programs in varied contexts, including permitting, day-to-day and strategic compliance counseling, facility purchase/sale, private-party claims, and civil and criminal enforcement. Specific areas of experience include: major and minor New Source Review pre-construction permitting; Title V operating permits; federal and state hazardous air pollutant programs; federal emission standards for nonroad engines; Risk Management Programs under the Clean Air Act §112(r); Reasonably Available Control Technology (RACT) requirements for facilities and consumer products; New Source Performance Standards (NSPS); and management of refrigerants and other Ozone-Depleting Substances. His air experience also includes less conventional issues such as odor, noise, and open burning.
As an active member of the State Implementation Plan Revision Advisory Committee (SIPRAC), Brian has worked with the Connecticut Department of Energy and Environmental Protection (DEEP) to develop, implement, and amend numerous air programs in that state. From 2009 to 2015, and from early 2022 to the present, he has served as Co-Chair of the Air Task Force of the Connecticut Business & Industry Association's Energy and Environment Council.
Brian has long worked with clients in navigating the emerging and uncertain world of climate change. He has worked with clients in a variety of industries in assessing the impact of state, federal, and international climate change policy and programs, and developing related strategy, advocacy, and compliance programs. Brian's climate change experience includes regulatory efforts to address climate change through pre-existing programs, as well as development of new approaches among industry, non-governmental organizations, and regulators.
Brian has extensive experience in representing clients facing Superfund and other liability claims, including complex contaminated sediment sites in urbanized tidal estuaries and rivers. He also has long counseled a client on a RCRA, TSCA and state remediation effort, natural resources restoration and site redevelopment at a large riverfront property following a century of intensive manufacturing use. He has particular experience with releases at petroleum bulk storage and dispensing sites, including emergency response, regulatory enforcement actions, and abutter lawsuits.
Brian has worked with numerous composting and other organics waste management facilities in achieving permitting, compliance and transaction objectives. He also has served as outside counsel to the U.S. Composting Council (USCC), where he was instrumental in developing the certification programs underlying the “compostable” logo found on many consumer plastic products today, and the “Seal of Testing Assurance” (STA) logo for compost products. He worked with other members of the USCC Legislative & Environmental Affairs Committee to develop a model zoning ordinance for composting facilities.
Brian has been listed in The Best Lawyers in America© in the area of Environmental Law since 2006, and in the area of Litigation - Environmental since 2011. Before joining the firm, he clerked for Judge Albert J. Engel, Jr. of the U.S. Court of Appeals for the Sixth Circuit.