Andrew D. Otis




Andrew Otis is a Partner in the New York office of Locke Lord LLP where he provides clients strategic and cost effective solutions to their environmental remediation, permitting and compliance needs. He advises clients in the commodity trading, mining and energy sectors and he has experience in international arbitrations involving claims outside the United States. He routinely helps clients navigate environmental risks, advising on numerous domestic and cross-border mergers and acquisitions, financings and real estate developments.

Andrew spent nine years at the U.S. Environmental Protection Agency (EPA), where he participated in writing rules under the Clean Air Act, including Maximum Achievable Control Technology (“MACT”) Standards under Title III of the Clean Air Act Amendments of 1990, including those applicable to refinery operations. He also played a key advisory role in policy areas such as global climate change, use of market mechanisms and economic analysis methodology.

Andrew has been recognized as one of the top environmental lawyers in New York by Super Lawyers and as a BTI Client Service All-Star. He has developed and taught classes in environmental policy and law at both Indiana University and Vassar College. He is a past Chair of the International Law Section of the New York State Bar Association and Co-Chair of its International Environmental Law Committee.

Andrew previously served as head of the environmental group at a prominent firm.

Representative Experience

  • Represented Petroleos de Venezuela S.A (“PDVSA”) subsidiary CITGO in environmental aspects of the sale of its asphalt business, including two asphalt refineries. Negotiated indemnities, including managing soil and groundwater contamination and activities required by a Petroleum Refinery Initiative (“PRI”) consent decree between CITGO and the United States Environmental Protection Agency (“EPA”). Advised on post-closing environmental claims by Buyer
  • Represented PDVSA as joint venture partner in the sale of theHOVENA refinery in the United States Virgin Islands, including negotiating necessary modifications to the HOVENSA PRI Consent Decree with the United States Department of Justice, the EPA and the government of the Virgin Islands and structuring indemnities. Negotiated with EPA the use of financial assurance by a trust for purposes of remediation
  • Represented CITGO in three rounds of financing wherein CITGO pledged all three of its refineries as collateral.  Supervised two rounds of lender due diligence, including site visits by lender counsel and consultants and virtual data rooms, for each refinery
  • With Dutch counsel, defended PDVSA subsidiary Refineria Isla, BV (“Isla”) in multiple litigations brought by local citizens groups over the course of ten years challenging Isla’s air and water emissions
  • Advised the Kazakhstan Ministry of Energy on sulfur management issues at the Tengiz oilfield operated by Tengizchevoil on behalf of a consortium of oil companies in which Chevron holds 50% and controls operations
  • Represented a chemical intermediates company in an indemnity capture program where it sought indemnification for environmental matters world-wide from asset sellers. Researched and analyzed claims in Canada in the United States, coordinated with facility staff to gather facts and analyze legal requirements, developed request for arbitration and participated in settlement negotiations

Professional Affiliations and Recognitions

  • Chair, International Law Section, New York State Bar Association
    • Co-Chair, International Environmental Law Committee
    • Environmental Law Section
  • Section of Environment, Energy, and Resources, American Bar Association
    • Vice Chair, Climate Change, Sustainable Development and Ecosystems Committee
  • Named, BTI Client Service All-Star
  • Named to New York Super Lawyers for Environmental (2013-2017)