Gwendolyn R. Keyes

• Serves as the Chief Counsel for a 190+ member trade association focused on the safe production, packaging and transportation of mission chemicals and advises on the day-to-day operations and interactions regarding regulatory matters and litigation strategies with EPA.
• Serves as primary environmental counsel for a global agricultural science company providing daily advice and counsel on compliance, remediation, and sustainability concerns arising from various state and federal laws.
• Represents multiple co-defendants, in a high-profile, first-of-its-kind Endangered Species Act litigation against the entire tire industry regarding the use of an anti-degradation chemical 6ppd in tires.
• Serves as environmental regulatory counsel for a medical technology services and solutions company providing strategic and legal advice with respect to federal and state environmental policy, including regarding air emission and pesticide registration for the use of ethylene oxide as a sterilization agent.
• Serves as primary environmental compliance counsel for a data center provider and operator successfully resolving to the client’s satisfaction numerous state-led permitting inquiries and enforcement actions involving water, air and waste concerns.
• Coordinates and provides counsel regarding a global worker protection investigation for a industry leading consumer products company.
• Successfully crafted and executed an engagement strategy for a leading global manufacturer focused on commercial print and advanced materials & chemicals, to have USEPA amend a chemical rule proposal to expand compliance flexibilities to enable continued operation of key business units.
• Negotiated a favorable settlement for a chemical manufacturer defending a citizen suit claim of non-compliance with the Clean Water Act.
• Drafted the defense strategy that facilitated a favorable Clean Air Act settlement for a large public power utility resulting in a significant reduction in penalties assessed.
• Successfully defended two waste disposal companies against the EPA’s claims of inadequate financial assurance under the Resource Conservation and Recovery Act.
• Assisted a newly elected local government client with reviewing the terms of the Clean Water Act Consent Decree, drafting a plan to address previous performance challenges with staff responsible for compliance and outlining a strategy to engage state and federal regulatory agencies in response to a citizen suit alleging noncompliance. Facilitated approval of a Consent Decree Modification which gave the client more time to implement cost effective remedies while also addressing the community's and NGO's environmental justice concerns.
• Conducted an internal investigation into alleged employee violations of an organization's policies and procedures that resulted in an employee agreeing to repay funds inappropriately obtained.
• Led the largest legal program within DHS, comprised of approximately 1500 attorneys and staff in 60 locations across the country providing legal advice to ICE client senior officials as they led a global team of nearly 20,000 employees committed to protecting national security and public safety via the enforcement of immigration and customs law.
• Managed the day‐to‐day operations of the EPA's nearly $8 billion budget and 15,000 employees in concert with other senior agency officials. Participated in the development and coordination of viewpoints of various stakeholders as the Agency finalized or proposed significant environmental regulations including the Clean Water Rule, the Clean Power Plan, the Definition of Solid Waste (DSW) Rule, Coal Combustion Residuals (CCR) Rule, Ozone NAAQS and the Worker Protection Standard.
• Operated as the lead enforcement official responsible for coordinating all civil and criminal aspects of environmental protection in conjunction with state partners and headquarters representatives in accordance with the statutory provisions of the Clean Water Act (CWA), Clean Air Act (CAA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Resource Conservation and Recovery Act, (RCRA) National Environmental Policy Act (NEPA) and other environmental laws.
• Served as the chief negotiator on numerous highly sensitive and complex environmental matters involving diverse stakeholder interests including a comprehensive and enforceable historic agreement with the State of Florida establishing, for the first time, a science-based protective limit (WQBEL) on NPDES permits controlling phosphorus pollution discharges into the Everglades thereby ending nearly twenty years of litigation.
• Served as the EPA's co-representative to the RESTORE Act Council and supervised the personnel tasked with addressing the ecosystem restoration and community resiliency in the Gulf of Mexico coastal region after the Deepwater Horizon Oil Spill.
• Managed to fairly balance the interests of law enforcement agencies, next-of-kin, the media and the community-at-large during the initiation and supervision of a year-long Special Civil Grand Jury Investigation into fifteen officer-involved fatalities that occurred within DeKalb County, Georgia within the span of one year.

The Legal 500 United States

• Recommended, Environment: Regulatory (2023-2024)
• Recommended, Environment: Litigation (2023)
• Recommended, Environment: Transactional (2023-2024)

Other recognitions

• Named to Forbes 2024 List of Top 200 Lawyers
• 2024 Dedication to Diversity and Justice Award from the ABA Section of Environment, Energy and Resources
• African American Federal Executive Association (AAFEA), Ebenezer Basset Award, 2017
• USEPA, Environmental Justice Champion of Change Award, 2015
• Atlanta Metropolitan, Combined Federal Campaign Leadership Award, 2012

• European Union Deforestation Regulation: What US companies should know, 24 September 2024
• US environmental law post-Chevron: Changes ahead, 15 July 2024
• EPA considers extending comment period for proposed rules regulating PFAS in RCRA corrective actions, 20 March 2024
• Continuing prioritization of environmental justice, EPA extends comment period for draft revision of Technical Guidance, 04 January 2024
• EPA’s newly adopted PFAS TSCA rules spell significant compliance obligations for businesses, 31 October 2023
• Governor Newsom enacts two California laws on disclosures of GHG emissions and climate-related financial risk, 11 October 2023
• Agencies are now required to consider greenhouse gas emissions in procurement decisions, budgets, and environmental reviews, 02 October 2023
• UN Climate Summit: What to watch for in Dubai, 28 September 2023
• EPA releases Draft National Strategy to Prevent Plastic Pollution, 09 May 2023
• New Executive Order advances federal environmental justice strategy and action: Impact on the regulated community, 02 May 2023
• Earth Day 2023: Converging on action in an environmental era like no other, 21 April 2023
• Proposed environmental and climate-related requirements for federal contractors – what general counsel need to know, 08 February 2023
• EPA delays setting PFAS effluent limitations, asks states to fill the temporary gap, 25 January 2023
• COP15 | Biodiversity: US Legal and Business Perspectives, 21 December 2022
• The historic Inflation Reduction Act makes significant changes to federal environmental law and programs, 19 August 2022
• "Implementing environmental justice—The ABA EJ Task Force," January 03, 2023
• "Environmental Justice Policy Gains Momentum Under the Biden Administration," February 22, 2021
• "Legal Challenge to Federal Ban on SEPs May Result in Change in Enforcement Policy," October 15, 2020
• "EPA Issues Compliance Advisory Regarding Pesticide Devices Making Claims to Kill the Novel Coronavirus," June 9, 2020
• "Medical Waste & COVID-19: Important Developments," March 26, 2020
• "Escalated Tension with Iran Heightens Cybersecurity Threat Despite Military De-Escalation," January 8, 2020
• "EPA's 20 Proposed Low-Priority and High-Priority Chemical Substances: Comments are Due November 2019," August 28, 2019
• "Water ISAC Releases Broader Cybersecurity Guidelines for Water & Waste Water Utilities," July 29, 2019
• "EPA Amends Freedom of Information Act Regulations," July 3, 2019
• "New Hazardous Waste Pharmaceutical Rule Imposes New Obligations on Health Care Providers," April 5, 2019
• "EPA Issues New Emergency Response Requirements for Community Water Systems," April 3, 2019
• "Significant Cyber Supply Chain Management Changes on the Horizon for Electric Utilities," October 31, 2018
• "DOT Aims to Create Flexible Regulatory Framework for Automated Vehicle Technology," October 11, 2018
• "FERC Raises the Threshold for Cyber Incident Reporting," July 24, 2018
• "Updated TSA Guidelines Suggest New Approach for Pipeline Cybersecurity," April 24, 2018
• "DC Circuit Decision Loosens Restrictions on Solid Waste," March 23, 2018
• "GAO Reports Challenges and Successes in Cybersecurity Framework Adoption," March 5, 2018
• "Federal Government Takes Steps to Shape Rules for Automated Vehicles," September 18, 2017

• “Federal EPA Policy Update.” Tri-State Environmental Law Conference, June 2024
• “Examining Recent Developments Under the Toxic Substances Control Act (TSCA): What Every Counsel for a Manufacturer/Importer of PFAS Must Know About the Latest EPA Reporting Requirements and Upcoming ‘New Use Rule’”, American Conference Institute (ACI) PFAS Regulations, Compliance and Litigation, May 2024
• "Compendium of environmental justice policies and actions in the Biden Administration," Gwen Keyes Fleming, Paul Wierenga, Sonakshi Kapoor and Michael Nagelberg, American Law Institute CLE presentation, February 16, 2023
• "60 Days' Notice: Citizen Suits after 50 years of the Clean Water Act (and short stories)" ABA's SEER 51st Spring Conference on Environmental Law, April 8, 2022
• "Priorities of the Biden-Harris Administration" ALI-CLE, February 10, 2022
• "What the Biden EPA's Environmental Justice Movement Means for Industrial Investors and Operators," June 22, 2021
• "Paths of Environmental Law and Environmental Justice: Where we need to go to ensure equal protection of everyone," ABA's SEER 50th Spring Conference on Environmental Law, April 30, 2021
• Environmental Law 2021, ALI CLE/Environmental Law Institute, February 24, 2021
• VNF Live, "Changes to Congressional Committee Leadership: They are Coming No Matter the Results of the Election," October 1, 2020
• APPA's Legal and Regulatory Conference, American Public Power Association, Portland OR, October 22, 2019
• "Managing Unused Pharmaceuticals: New Obligations on Healthcare Providers, Expanded Definition of Healthcare Facility," June 19, 2019
• "Race and the Law,” Vermont Law School's Black Law Student Association, South Royalton VT, February 1, 2019