Thomas R. Wood

Thomas R. Wood

Special Counsel
Portland, OR

About Tom

Before becoming an attorney, I ran several small businesses. Combined with my strong technical background, this gives me an understanding that what most companies need is not a legalese answer, but a practical solution, a clearly articulated strategy, and good communication skills. Providing this type of guidance and client response is what I enjoy most about what I do and after 29 years of practice, I have the depth of experience to deliver for clients.

My practice focuses predominantly on air-permitting matters, although I also have extensive experience with EPCRA reporting, waste regulation, and stormwater and wastewater management. I have handled all types of enforcement (civil, criminal, and citizen suit) and worked on multiple high stakes nuisance matters. While my work is predominantly in Oregon, Washington, California, Nevada, and Montana, I have assisted clients on issues across the United States. I have worked in all 10 EPA regions on a broad variety of permitting and enforcement matters.

Under state and federal Clean Air Act matters, I have helped clients find solutions to Title V permitting and compliance, new source review (including Prevention of Significant Deterioration or PSD, nonattainment and maintenance area), National Emission Standards for Hazardous Air Pollutants (NESHAP or MACT standards), New Source Performance Standards (NSPS), Acid Rain, Reasonably Available Control Technology (RACT) assessments, Regional Haze, greenhouse gas regulation, nuisance odor, nuisance dust, emission offsets, and many other esoteric aspects of air regulation. I have assisted companies on dozens of Section 114 information requests and similar state administrative subpoenas. This includes work on California Air Resource Board (CARB) consumer products standards as well as state and local equivalent standards such as those developed by the South Coast Air Quality Management District.

I worked my way through college loading and unloading trucks. After leaving Stanford, I worked in New York City doing specialty contracting work. People often ask why I left that work to go to law school. The reason was that I saw the scope of regulations growing ever more complex and I wanted to help others navigate the tortured pathways so that they could better focus on their businesses. I measure success by finding a cost-effective solution that leaves my clients able to do what they need to do and leaves the agency recognizing my clients’ compliance efforts.

I have had the pleasure of working with some of the nation’s leading semiconductor, aerospace, cement, steel, wood products, pulp and paper, chemical, energy, glass, oil and gas, motor vehicle, landfill, renewable fuel, biotech, data, food processing, equipment manufacturing, and retail companies. I like nothing better than to help manufacturers excel in making the best products in the world, right here in the United States.

As stated by natural resources & environment clients, “He is incredibly knowledgeable, seasoned and practical. He is excellent in communication, is responsive, clear and pragmatic and understands the business, the political and administrative law requirements.”

Tom’s air quality and environmental enforcement expertise is unrivaled across the US.”

“Tom brings excellence to every environmental issue and counsels our company with an excellent view of what makes sense for our business.” (Chambers USA)         


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  • Representation of multiple companies in FAA enforcement actions related to transportation of hazardous materials.
  • Representation of multiple companies in CARB and SCAQMD Consumer Product VOC regulation investigations and enforcement actions.
  • Permitting of multiple power plants in California, Oregon, Nevada, and Washington.
  • Permitting and compliance work for multiple cement plants in Washington, Oregon, Nevada, Idaho, Texas, Arkansas, Kansas, and Nebraska.
  • Permitting and compliance work for steel and nonferrous metals foundries and forges in West Virginia, New Hampshire, Ohio, Michigan, Texas, California, Oregon, Nevada, Pennsylvania, Kentucky, and Washington.
  • Permitting of LNG terminal 14 miles off California coast.
  • Civil enforcement action under Clean Air Act for alleged PSD and NSPS violations involving 8 states and EPA Headquarters.
  • Permitting and compliance work for multiple wood products manufacturing facilities in Louisiana, Arkansas, North Carolina, Montana, California, Washington, and Oregon.
  • Permitting and compliance work for multiple semiconductor fabs in the Western U.S. 
  • Criminal enforcement action against heavy equipment manufacturing company for alleged NESHAP violations.
  • Numerous Clean Air Act Section 114 responses on behalf of companies across the U.S. 
  • Numerous voluntary self-disclosures for violations of Clean Air Act and Emergency Planning and Community Right-to-Know Act.
  • Defense of nuisance odor allegations at several major manufacturers.
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Honors & Activities

Professional Honors and Activities

  • Named by Best Lawyers® as Environmental Law “Lawyer of the Year,” Portland, 2012 and 2016
  • Included in The Best Lawyers in America® (Environmental Law, Litigation—Environmental), 2008–2024
  • Listed in Oregon Super Lawyers® (Environmental, Energy & Natural Resources), 2008–2019
  • Selected as one of “America’s Leading Lawyers for Business” (Oregon) by Chambers USA (Environment), 2006–2023
  • Associated Oregon Industries Environmental Excellence Award, 2011
  • Chairperson, Associated Oregon Industries Air and Energy Committee
  • Chair, Stoel Rives Air Team

Civic Activities

  • Board of Directors, Literary Arts
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Insights & Presentations

Insights & Presentations

  • “Cleaner Air Oregon: Lessons Learned,” Business & The Environment CONFERENCE · EXPO, Northwest Environmental Business Council (NEBC), December 7, 2022
  • “Carbon Regulations and Markets,” Pacific Northwest Timberlands Management: Regulations, Litigation, and Business Considerations, The Seminar Group, March 2022
  • “Regulating GHGs in Oregon and Washington: New Developments,” Business & The Environment CONFERENCE · EXPO, NEBC, December 2021
  • “Oregon’s Cap and Reduce Program: what’s on the GHG Horizon?,” Business & The Environment CONFERENCE · EXPO, NEBC, December 2020
  • “Cap and Trade: Gone, But Not Forgotten,” Business & The Environment CONFERENCE · EXPO, NEBC, Portland, OR, December 2019
  • “Market-Based Strategies for Greenhouse Gas Reduction,” Climate Change Mitigation and Adaptation: Perspectives from the West, Stoel Rives LLP/Environmental Law Institute, Portland, OR, June 2019
  • “Putting a Price on Carbon: Understanding Oregon’s Proposed Cap and Trade Program,” Business & The Environment CONFERENCE · EXPO, NEBC, Portland, OR, December 2018
  • “Air Regulations, Biomass, and Carbon Markets,” Pacific Northwest Timberlands Management, The Seminar Group, Portland, OR, March 2016
  • “Advanced Air Toxics,” Northwest Environmental Conference & Tradeshow, Portland, OR, December 2017
  • “Clean Air Act Regulation and Biomass Fuels,” Pacific Northwest Timberlands Management, The Seminar Group, Portland, OR, April 2016
  • “Climate Change Overview - The Regulatory Playing Field,” Climate Change Policy Outlook Conference, September 2014
  • “Clean Air Act Regulation and Biomass Fuels,” Pacific Northwest Timberlands Conference, Portland, OR, April 2014
  • “Advanced Air Topics,” Northwest Environmental Conference, Portland, Oregon, Dec. 2013
  • “Boiler MACT Compliance Challenges,” Air & Waste Management Association Conference, Seattle, WA, May 2013
  • “Environmental Permitting Considerations for Natural Gas Development,” Natural Gas Development Conference, Seattle, WA, March 2013
  • 2013 Oregon Law Institute chapter on Air Permitting and Regulation
  • “Greenhouse Gas Regulatory Developments and Trading Mechanisms,” National Council for Air & Stream Improvement, Vancouver, Washington, September 2008 (Best Presentation Award)
  • “Geologic Carbon Sequestration: Property Rights and Regulation,” Rocky Mountain Mineral Law Institute, Aspen, CO, July 2008
  • EPA Revises New Source Review Rules, September 2005
  • EPA Boiler and Combustion Turbine Standards, March 2005, Federal New Source Review Enforcement, February 2002

Related News & Publications

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