Shannon S. Broome

Managing Partner, San Francisco Bay Area
San Francisco Bay Area Office
Washington, DC Office
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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.

  • Representation of major oil company on regulatory advocacy on Clean Air Act regulation under Section 112(f) for residual health risk, achieving resolution that saved the company tens of millions of dollars.
  • Representation of Texas Oil & Gas Association in litigation in the US Court of Appeals for the DC Circuit, challenging EPA's New Source Performance Standards for Oil and Gas operations (fracking).
  • Representation of Renewable Fuels Association in litigation challenging Californias Low Carbon Fuel Standard (LCFS) in the US Court of Appeals for the Ninth Circuit, following a victory in district court determining that the LCFS violates the Commerce Clause of the US Constitution.
  • Representation of major automobile manufacturer in all Clean Air Act permitting in Michigan, Indiana, New York and Illinois.
  • Representation of major household product manufacturer in environmental enforcement of the Clean Air Act.
  • Representation of midstream oil and gas company in enforcement action in northwest state over environmental and Army Corps of Engineers permitting requirements.
  • Representation of Midwest manufacturing facility on Clean Air Act permitting, successfully obtaining permit in the face of initial modeling indicating violation of ambient air quality standards.
  • Representation of major manufacturing company on Waxman-Markey climate change cap-and-trade legislation.
  • Representation of joint venture in achieving passage of legislation in California allowing for treatment of on-board recycled oil without treating it as disposal of hazardous waste.
  • Representation of utility in enforcement before California air district, negotiating favorable settlement of same.
  • Representation of coalition of 20 trade associations in eight challenges to EPA's greenhouse gas regulatory approach in the US Court of Appeals for the DC Circuit, which is now awaiting the Supreme Court's determination as to whether to grant certiorari.
  • Representation of investor group in large utility unit in negotiating transaction terms related to environmental compliance obligations under Mercury Air Toxics Rule and other regulatory requirements.


Chambers USA, 2012–2015

Daily Journal

Daily Journal, California's 100 "Top Women Lawyers," 2014
Super Lawyers, 2014
Co-author, Managing Your Title V Permit, The Clean Air Act Handbook, American Bar Association, 3rd. ed.
Co-author, Life After Title V Permit Issuance: You've Received Your Permit, Now What Do You Do?, The Clean Air Act Handbook, American Bar Association, 2nd. ed.
Legal Issues in Preparing Clean Air Act Title V Permit Applications, Clean Air Deskbook, American Bar Association
Co-author, The Clean Air Act Operating Permit Program: A Handbook for Counsel, Environmental Managers and Plant Managers, American Bar Association
Firm News
June 4, 2015
Moderator | New Source Performance Standards for Methane From Oil and Gas Sector Under Section 111(b) of the Clean Air Act and Potential Implications for Existing Sources | ELI Conference: In the Hot Seat: Drilling into the Administration's Plans to Regulate Methane Emissions From the Oil and Gas Sector | Washington, DC
September 16, 2014
Presenter | RMP and PSM in Context – the 1990 Amendments | Chemical Safety and Security Seminar | Houston, Texas
October 10–13, 2012
Presenter | Overview of Select Federal Rulemakings Implicating Greenhouse Gases | 20th Section Fall Meeting: The ABA Environment, Energy, and Resources Law Summit | Austin, Texas
August 15, 2012
Regulatory Drivers for CO2 Control, Navigating the Impacts of PSD, Title V, and Other Clean Air Act Regulatory Requirements for GHGs, Coal-Gen Annual Conference, Louisville, Kentucky
June 4, 2012
Course on Effectively Handling Government Inspections of Ethanol Production Facilities, Trainer, Renewable Fuels Association Seminar at the Federal Ethanol Workshop, Minneapolis, Minnesota
January 24, 2012
Moderator | Hot Topics in Air Enforcement and Priorities for 2012 | ABA Air Quality Committee Teleconference
December 1–2, 2011
Faculty | Title 1 – NAAQS, ALI-ABA Course of Study – Clean Air: Law, Policy, and Practice | Washington, DC
February 28, 2011
How will EPA’s GHG Tailoring Rule Impact Your Business? Speaker, National Ethanol Conference, Scottsdale, Arizona
October 20–23, 2005
Hot Air Balloons. Traditional and Cutting Edge Air Emission Regulation: EPA’s New Source Review Reforms and California’s CO2 Regulation, Speaker and Panel Moderator, California State Bar Annual Conference on Environmental Law at Yosemite, Yosemite, California
March 2004
Symposium on Shaping Environmental Policy: Science, Information, and the Law, Speaker, UCLA School of Law Evan Frankel Environmental Law and Policy Program, Los Angeles, California
October 23–26, 2003
New Source Review Improvement Rule and Equipment Replacement Provision Federal Litigation Update, Speaker and Program Moderator, California State Bar Annual Conference on Environmental Law at Yosemite, Yosemite, California
June 22–26, 2003
After Permit Issuance: Permit Revision Requirements Under Title V of the Clean Air Act, Speaker, Air & Waste Management Association 96th Annual Conference and Exhibition, San Diego, California
July 21, 1995
Subcommittee on Oversight and Investigations, Committee on Commerce, US House of Representatives, Title III of the Clean Air Act Amendments of 1990, Invited Testimony regarding EPAs implementation of hazardous air pollutant provisions of the Clean Air Act Amendments of 1990, Washington, DC


  • JD, University of California, Berkeley, School of Law, Order of the Coif
  • BS, University of California, Los Angeles

Bar Admissions

  • California
  • District of Columbia
  • New York

Court Admissions

  • US Court of Appeals, District of Columbia Circuit
  • US Court of Appeals, Fifth Circuit
  • US Court of Appeals, Ninth Circuit
  • US Court of Appeals, Tenth Circuit
  • US District Court, Eastern District of California
  • Supreme Court of California



Daily Journal

California's 100 "Top Women Lawyers," 2014
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  • American Bar Association, Section of Environment Energy and Resources, Co-Chair Climate Change, Sustainable Development and Ecosystems Committee
  • Environmental Law Section of the California Bar

Federal Entities/Agencies

Department of Energy
Department of Transportation
Office of Management and Budget
US Environmental Protection

State and Local Entities/Agencies

   - Air Resources Board
   - Bay Area Air Quality
      Management District
   - CalEPA
   - Department of Industrial
   - Legislature
   - Occupational Safety and Health
   - Office of Environmental Services
   - San Diego Air Pollution Control
   - San Joaquin Valley Air Pollution
      Control District
   - South Coast Air Quality
      Management District
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
Ohio EPA
Puget Sound Clean Air Agency
Texas Commission on Environmental Quality
Utah Department of Environmental Quality
Wyoming Department of Environmental Quality

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