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Hunton Andrews Kurth LLP

Shannon S. Broome

Shannon S. Broome



  • Air
  • Chemicals, Products and Hazardous Materials
  • Climate Change Law and Policy
  • Climate Change

WSG Practice Industries


Hunton Andrews Kurth LLP
California, U.S.A.


Shannon is a trusted advisor to her clients, who describe her as an “outstanding lawyer—very practical, effective, extremely smart and incredibly knowledgeable,” in Chambers USA, 2016.

Shannon is the managing partner of the firm’s San Francisco office and leads the firm’s California environmental practice.  Her prior experience as a chemical engineer in the oil and gas industry affords her unparalleled insights into the development of regulations and counsel on environmental, health and safety issues. Shannon also maintains an office in Washington, DC. Splitting her time between these offices allows her to help her clients wherever they may be. Shannon’s work focuses on permitting, enforcement, environmental incident response, and regulatory advocacy and litigation.

A nationally recognized authority on Clean Air Act matters, with more than 25 years of experience addressing all aspects of the act, Shannon represents clients in a variety of manufacturing and energy sectors, including oil and gas, chemical, paper, automotive, power generation and utilities. Shannon also advises companies in preparation for and responding to environmental incidents and under federal and state process safety management and risk management plan regulations.

Highly regarded for her litigation practice challenging and defending EPA and California regulations and permits before federal and state appellate courts, in 2018, she was named to The National Law Journal’s list of “Energy & Environmental Trailblazers.” She is also lauded for her deep knowledge of environmental enforcement matters, and is respected by her Fortune 100 clients for her solid advice on compliance advocacy. She was previously an engineer for Chevron, USA, in Los Angeles, California.

Shannon is admitted in the Supreme Court of California; US District Court, Eastern District of California; and US Courts of Appeals for the District of Columbia, Ninth and Tenth Circuits.

Shannon is a contributor to the firm’s environmental blog, The Nickel Report.

Relevant Experience

  • Represents oil and gas company client in climate change litigation in California, in claims by cities and counties that her client, along with other oil and gas companies, is liable under state common law nuisance theories.
  • Represents oil companies in complex Clean Air Act permitting and enforcement under the Prevention of Significant Deterioration, Nonattainment New Source Review, minor source, and Title V permitting programs.
  • Represents major mobile fleet operator in enforcement of California Air Resources Board onroad and off-road emissions regulations.
  • Represented major construction equipment manufacturer in resolving enforcement action under Clean Air Act Title II, related to import and marketing in the United States.
  • Represents numerous off-road and light and heavy duty vehicle manufacturers on compliance with Title II federal regulations and California Air Resources Board regulations.
  • Represents companies subject to the California Low Carbon Fuels Standard (LCFS) and federal Renewable Fuels Standard (RFS) programs on compliance requirements and in enforcement actions.
  • Represents an industry trade association on EPA’s revision of its risk management plan (RMP) regulations for chemical accidents, including arguing in defense of a regulation issued by the Pruitt EPA to delay the prior administration’s RMP regulatory revisions before the U.S. Court of Appeals for the D.C. Circuit.
  • Represents major trade groups, including auto industry, oil and gas, chemical, aerospace, steel, and general manufacturing trade associations, before EPA on Clean Air Act rulemakings, including litigating dozens of such regulations in the U.S. Court of Appeals and arguing in the D.C. Circuit in both challenging and defending Clean Air Act rules.
  • Represents the steel industry, the auto industry, and turbine manufacturers, among others, in rulemaking to address residual risk and technology reviews under Clean Air Act Section 112.
  • Represented refinery in incident response to air and ground release that created vapor cloud over resort community, including managing release reporting, permitting implications, and coordination of communication with state and federal regulators.
  • Represented refinery in interface with federal and state regulators in light of significant equipment malfunction with potential to lead to several days of flaring.
  • Represents several refineries and upstream oil and gas operations in permitting and enforcement actions before California air districts.
  • Represents major oil trade association in regulatory advocacy before EPA and in the US Court of Appeals for the DC Circuit related to the agency’s regulations of upstream and midstream emissions of volatile organic compounds and methane.
  • Represented midstream oil and gas company in enforcement action in northwest state over environmental and Army Corps of Engineers permitting requirements.
  • Represented major household product manufacturer in environmental enforcement of the Clean Air Act.
  • Represents major automobile manufacturer on all air permitting and enforcement for its manufacturing plants in Michigan, Indiana, New York and Illinois.
  • Represents major automobile company on EPA greenhouse gas and National Highway Transportation Safety Administration on corporate average fuel economy (CAFE) standards.
  • Represented 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.
  • Represented trade association in litigation challenging California’s Low Carbon Fuel Standard (LCFS) in US district court, the US Court of Appeals for the Ninth Circuit and the Supreme Court.
  • Represented coalition of 20 trade associations in eight challenges to EPA’s greenhouse gas regulatory approach in the US Court of Appeals for the District of Columbia Circuit, which is now awaiting the Supreme Court’s determination as to whether to grant certiorari.
  • Represented utility in enforcement before California air district, negotiating favorable settlement of same.
  • Represented 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.
  • Represented major manufacturing company on Waxman-Markey climate change cap-and-trade legislation.
  • Represented investor group in large utility unit in negotiating transaction terms related to environmental compliance obligations under Mercury Air Toxics Rule and other regulatory requirements.
  • Represented Texas Oil & Gas Association in litigation in the US Court of Appeals for the District of Columbia Circuit, challenging EPA’s New Source Performance Standards for Oil and Gas operations (fracking).
  • Represented Midwest manufacturing facility on Clean Air Act permitting, successfully obtaining permit in the face of initial modeling indicating violation of ambient air quality standards.

Bar Admissions

  • California
  • District of Columbia
  • New York


BSChE, University of California, Los Angeles, 1985
Areas of Practice

Air | Chemicals, Products and Hazardous Materials | Climate Change | Climate Change Law and Policy | Crisis Management | Energy and Environmental Litigation | Energy Litigation | Environmental | Land Use | PFAS Interdisciplinary Team | Pipeline | Regulatory | Water

Professional Career

Professional Associations

  • Executive Director, Air Permitting Forum
  • Member, Auto Industry Forum (subset of the Air Permitting Forum)
  • American Bar Association’s Section on Energy, Environment, and Resources
  • Co-chair, Climate Change, Sustainable Development, and Ecosystems Committee, American Bar Association’s Section on Energy, Environment, and Resources, 2013–2016
  • Vice-chair, Programming of the Air Quality Committee, American Bar Association’s Section on Energy, Environment, and Resources, 2011–present
  • Member, Environmental Law and Public Law Sections of the California Bar Publications

Professional Activities and Experience

  • Recognized as an Energy and Environmental Trailblazer, National Law Journal, 2018
  • Named among the Top Women Lawyers in California, Daily Journal, 2014, 2017
  • 2017 Chambers USA Environment Law Firm of the Year
  • Recognized as a Leader in Climate Change, Nationwide, Chambers USA, 2012-2017
  • Recognized as a Leader in Environment Law, District of Columbia, Environment, Chambers USA, 2012-2017
  • Named Among California’s Top 100 Lawyers, Daily Journal, 2014
  • Named Among California’s 100 Top Women Lawyers, Daily Journal, 2014, 2017
  • Selected as a Super Lawyer for Environmental Law, California Super Lawyers magazine, 2014-2016. A description of the selection methodology can be found on Super Lawyers’ webpage.


  • Practitioner Insights: California Tackles Climate Change, Bloomberg BNA: Daily Environment Report
  • New GHG Rule for Oil and Gas Facilities, Daily Journal
  • Calif.’s Cap-and-Trade System: Allowable Fee or Impermissible Tax, The Recorder
  • Legal Issues in Preparing Clean Air Act Title V Permit Applications, Clean Air Deskbook, American Bar Association
  • Food v. Fuel: Are Legal Attacks on the Renewable Fuel Standard Just a Bunch of Empty Calories? Natural Resources & Environment
  • EPA Reversal Of Refrigerant Requirements Is Good For Cos., Law360
  • New Law Regulates Short-Lived Pollutants, Daily Journal (Subscription),
  • Assessing Repeal of OSHA’s Injury Reporting Rule, Law360
  • As Jurisdictions Like California Sort Out Regulation of Hydraulic Fracturing, NIMBY Approaches Pop Up in Other Jurisdictions, Environmental Law News
  • Managing Your Title V Permit, The Clean Air Act Handbook, Fourth Edition, American Bar Association
  • What to Know About Proposed Chemical Safety Reg Changes, Law360
  • Socially-Distant Operation Of Critical Infrastructure, Facility Executive
  • EPA’s Missed Opportunity to Ground Its GHG Tailoring Rule in the Statute: What the Situs Argument Would Mean for the Future of the PSD Program, ELR News & Analysis
  • 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.
  • The Clean Air Act Operating Permit Program: A Handbook for Counsel, Environmental Managers and Plant Managers, American Bar Association
  • Managing Your Title V Permit, The Clean Air Act Handbook, American Bar Association, 3rd. ed.
  • State Air Board Plans New Mobile Source Regulations, Daily Journal
  • EPA Finalizes Reconsideration Rules for Boilers and Solid Waste Incinerators but Issues Remain, Trends E-Magazine

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