Chris Thomas practices environmental litigation, mediation and counseling on behalf of corporate, industrial and municipal clients throughout the United States. His practice is concentrated in the areas of hazardous substances, hazardous waste, groundwater contamination, industrial compliance, environmental permitting for new and expanded facilities, and the environmental aspects of real estate and corporate transactions. His practice covers major federal environmental statutes including the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), the Clean Water Act and the Clean Air Act, as well as numerous state counterparts and tort theories.

Chris has defended or prosecuted cases under CERCLA, RCRA, and parallel state law and tort theories pertaining to more than 30 sites throughout the country. He has directed the completion of remedial investigations and feasibility studies, and negotiated consent decrees and agreements with the US Environmental Protection Agency, the US Department of Justice and parallel state agencies.

His clients have included companies in the paper, natural gas transmission, semiconductor manufacturing, specialty chemical, base metals, mineral processing, heavy manufacturing, real estate and hazardous waste recycling industries, and municipalities including the City of Phoenix, Arizona.

Chris is one of seven members of the Arizona Governor’s Regulatory Review Council, which provides final review of most state agency rules. He serves as a disciplinary hearing officer for the Arizona Supreme Court and is a former member of the State Bar’s Rules of Professional Conduct Committee. Chris is a member of the boards of Southwest Center for Human Development, Arizona’s largest non-profit child development agency, and the Gompers Habilitation Center, which serves adults and children with mental and physical disabilities. He previously served on the boards of the Arizona Center for Disability Law, The Nature Conservancy, Arizona Chapter, and the Upward Foundation school for special needs children.

Chris is listed in The International Who’s Who of Environment Lawyers 2011, Chambers USA: America’s Leading Business Lawyers 2011 and The Best Lawyers in America 2012. He has been listed in Southwest Super Lawyers each year since 2007.

Representative Experience

• Representing Next Era Energy Resources, LLC, North America's largest producer of renewable energy, on siting and environmental issues pertaining to its proposed 99 MW wind farm in northern Arizona, including successful prosecution of an application for a certificate of environmental compatibility before the Arizona Power Plant and Transmission Line Siting Committee.
• Defending the City of Phoenix in a $120 million CERCLA cost recovery case brought against Phoenix and 71 other parties by a West Valley irrigation district, alleging that the defendants caused or contributed to groundwater contamination impacting its wells.Ÿ 
• Counseling Enhanced Oil Resources, the developer of a proposed helium plant in southeast Arizona, on environmental permitting issues including potential air permitting and greenhouse gas regulatory matters.Ÿ 
• Representing three industrial potentially responsible parties with regard to the Broadway-Pantano Landfills state Superfund site. Ÿ 
• Negotiating the first prospective lessee agreement with the United States on behalf of the developer of a luxury resort within the former Empire Canyon mine site in Deer Valley, Utah, in a transaction that served as a pilot project for US EPA's new Environmentally Responsible Redevelopment and Reuse (ER3) program.Ÿ 
• Representing the owner of a former copper mine and uranium mill in southern Arizona on issues arising out of US EPA's assessment of the site for potential NPL listing and regulation of an industrial tenant under Arizona's aquifer protection permit program.Ÿ 
• Defending MeadWestvaco, former owner of several Alabama iron foundries, in a multiparty CERCLA case regarding PCB and lead contamination in Anniston, Alabama, and in negotiation of an administrative consent agreement with EPA Region IV calling for removal of lead and PCB contamination in residential yards.Ÿ 
• Representing the City of Phoenix in CERCLA cost recovery, cleanup and negotiations matters pertaining to the 19th Avenue Landfill, Estes Landfill, Motorola 52nd Street, Sky Harbor Airport and Phoenix-Goodyear Airport hazardous substance sites including litigation resulting in recovery of $29.2 million of response costs and a successful, precedent-setting trustee liability case that prompted Congressional amendment of CERCLA.Ÿ 
• Representing OM Group, the world's largest cobalt producer, with regard to RCRA enforcement by EPA Region VIII and a Bureau of Indian Affairs lease proceeding pertaining to the OMG Apex cobalt-tungsten recycling facility on tribal land near St. George, Utah.
• Representing a leading national home builder in land use litigation arising out of a newly incorporated city's attempt to assess impact fees precluded by a pre-existing development agreement between the builder and the city's predecessor county.