
Susan Rainey uses her experience as a former project manager in the Texas Commission on Environmental Quality (TCEQ) Voluntary Cleanup Program (VCP) to assist clients in evaluating and addressing environmental issues. Named in Chambers USA for Environmental Law in 2010-2012, Ms. Rainey's experience includes analyzing environmental risks and liabilities and drafting environmental provisions of transaction documents to protect clients in all types of transactions. Transactions include real estate acquisitions and sales, lending, foreclosures, and corporate transactions in Texas and more than twenty other states, as well as analyzing environmental insurance availability and coverages. She has also assisted clients in redeveloping brownfield sites, conducting environmental assessments and remediation, pursuing closure through voluntary cleanup, corrective action, brownfields and other regulatory programs in states across the country, and seeking out funding, reimbursement or tax credits where available. These environmental assessments and remediation projects have included work with chlorinated solvents; petroleum and underground storage tanks (USTs); soil, soil gas, and groundwater contamination; indoor air vapor intrusion risks; vapor mitigation systems and vapor barriers; asbestos; lead and lead based paint; and polychlorinated biphenyls (PCBs). In Texas, she has worked with clients to obtain Municipal Setting Designations (MSDs) to achieve regulatory closure through the VCP and Corrective Action Section. She has also counseled clients on navigating state and federal superfund information requests, potentially responsible party (PRP) group agreements, and agency or PRP cleanups.
Ms. Rainey frequently assists clients with commercial and residential property condition and building management issues, including indoor air, mold, radon, asbestos containing materials (ACM), and lead based paint (LBP) assessment, mitigation, and abatement, and counsels clients on managing tenant relations regarding these issues. Her experience includes environmental regulatory work, including permit transfers, responding to notices of violation, arranging for and evaluating environmental audits, assisting with abatement plans, reviewing operations and maintenance plans (O&M Plans), and ensuring compliance with a broad range of environmental regulatory requirements at both the state and federal levels.
Education
- J.D., The University of Texas School of Law, 2005
Order of the Coif - B.A., Environmental Science and Biology, Boston University, 1996
Bar Admissions
Representative Experience
- Environmental Compliance Work – Working with clients to review environmental audits, Phase I Environmental Site Assessments, Phase II and Limited Site Assessments, and other environmental information to help clients achieve compliance with environmental laws and regulations.
- Environmental Regulatory Work – Assisting clients with assessments and remediation in state and federal environmental agency programs including voluntary cleanup, corrective action, and superfund programs; assisting with permitting and enforcement issues before regulatory agencies; assisting with lead based paint, asbestos, and mold remediation activities.
- Environmental Transactional Work – Assisting clients in reviewing due diligence information and environmental insurance availability and coverage in corporate, real estate, and lending transactions to assess environmental risks and find efficient, cost-effective, and appropriate solutions to environmental issues.
Publications & Presentations
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Co-Author,
"
Locke Lord QuickStudy: EPA Forges Ahead with New Emission Rules for Power Plants
,"
Locke Lord
(January 3, 2011)
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Co-Author,
"Avoid Environmental Issues in Foreclosures,"
Texas Lawyer
(March 21, 2011)
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Co-Author,
"Client Alert: SEC Guidance Highlights Need for Climate Change-Related Disclosures,"
Locke Lord
(February 12, 2010)
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Co-Author,
"Client Alert: Supreme Court Narrows the Interpretation of CERCLA “Arranger” and Joint and Several Liability,"
Locke Lord Bissell & Liddell LLP
(May 8, 2009)
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Client Presentation,
"Evolving Laws on Electronic Waste: WEEE, RoHS, and Other Laws,"
presented with James Kean
(2009)
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Client Presentations,
"Environmental Issues Impacting Transactions,"
presented with Elizabeth Mack
(2008-2009)
Professional History
- Associate, Locke Lord LLP
- Project manager, Voluntary Cleanup and Innocent Owner/Operator Programs, Texas Commission on Environmental Quality (2000 - 2002)
- Coordinator, Petroleum Storage Tank Responsible Party, Remediation Section, Texas Commission on Environmental Quality (1999 - 2000)
Professional Affiliations & Achievements
- Named, Chambers USA Client’s Guide of America’s Leading Lawyers for Business (Environment)
- Named, “Associate to Watch,” Chambers USA for Environmental Law (2009-2012)
- Member, Commercial Real Estate Women (CREW) Dallas
- Member, Dallas Bar Association
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