Shannon S. Broome is the managing partner of the firm's San Francisco Bay Area office and is a partner in the Washington, DC office as well. She counsels and represents clients on a range of environmental matters before local and federal courts and administrative agencies. She heads the firm's Air Quality and Climate Change practice and co-leads the Environmental Law and Policy practice. Being co-located in the San Francisco Bay Area and Washington, DC offices allows her to serve clients nationally and in California, a jurisdiction that is frequently at the forefront of environmental regulation. Her practice focuses on three primary areas: government and regulatory affairs, compliance counseling and enforcement defense, and environmental litigation.
Shannon advocates on behalf of her clients on numerous federal and state environmental statutes. 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 focuses on implementation of all aspects of the Clean Air Act, and related statutes, including the Energy Policy Act of 2005, and the Energy Independence and Security Act of 2007. She also routinely advises on the California Global Warming Solutions Act (AB32). California's Low Carbon Fuels Standard and the California Environmental Quality Act.
Shannon has been involved in the development of virtually every major regulation issued following enactment of the Clean Air Act Amendments of 1990, an experience she uses to provide her clients advice on compliance and represent them in enforcement actions. She was selected by the US Environmental Protection Agency (EPA) to serve on numerous committees and stakeholder groups to develop regulations such as the New Source Review, NESHAP, and Title V operating permit regulations.
In addition, 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. In her work as counsel for General Electric, 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 experienced in environmental enforcement matters.
Shannon's clients describe her as an "outstanding lawyer – very practical, effective, extremely smart and incredibly knowledgeable" (Chambers USA).
Shannon serves as the executive director of the Air Permitting Forum, a group of Fortune 100 companies dedicated to the smooth implementation of Clean Air Act permitting and regulatory programs. In addition, she directs a sub-entity of the Forum, the Auto Industry Forum, which advocates on behalf of the auto industry on all CAA stationary source issues.
Prior to joining Katten, Shannon was counsel and manager of Clean Air Act programs for the General Electric Company, where she was responsible for Clean Air Act 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.
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 sub-group 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 deeply 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 holds leadership positions in the American Bar Association's Section on Energy, Environment, and Resources, serving as co-chair of the Climate Change, Sustainable Development, and Ecosystems Committee (2013–2016); as vice-chair for Programming of the Air Quality Committee (2011–2015); and on the Planning Committee for the 22nd Fall Conference (2014).
Shannon has written several articles and regularly speaks on environmental issues. She is a co-author of The Clean Air Act Operating Permit Program: A Handbook for Counsel, Environmental Managers, and Plant Managers (ABA, 1993).
Shown below is a selection of Shannon’s engagements.
Department of Energy
Department of Transportation
Office of Management and Budget
US Environmental Protection
- Air Resources Board
- Bay Area Air Quality
- Department of Industrial
- Occupational Safety and Health
- Office of Environmental Services
- San Diego Air Pollution Control
- San Joaquin Valley Air Pollution
- South Coast Air Quality
Colorado Department of Health and Environment
Florida Department of Environmental Protection
Indiana Department of Environmental Management
Michigan Department of Environmental Quality
New York Department of Environmental Conservation
Puget Sound Clean Air Agency
Texas Commission on Environmental Quality
Utah Department of Environmental Quality
Wyoming Department of Environmental Quality