As a former US Environmental Protection Agency (EPA) attorney, Sam utilizes his agency, regulatory, enforcement, and practical experience to help his clients navigate environmental, energy, natural resource, sustainability, and climate-related concerns associated with US- and international-based facilities and operations. Sam’s practice focuses on three core areas – navigating federal and state environmental laws, implementing sustainability and climate-related decarbonization strategies, and minimizing legal and reputational risks associated with international project development and operations. He is a former attorney with the EPA, in the Office of Regional Counsel in San Francisco (Region 9) and in New York (Region 2), and the Office of General Counsel in Washington, DC.

In the US, he assists clients with complying with federal and state environmental laws, including compliance counseling, obtaining regulatory authorizations, facility and corporate audits, project and transactional due diligence, citizen suits, administrative and civil enforcement defense, and litigation. His clients rely on his experience when navigating the Clean Water Act (CWA); the Resource Conservation and Recovery Act (RCRA); the Safe Drinking Water Act (SDWA); the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); the Clean Air Act (CAA); the Toxic Substances Control Act (TSCA); the National Environmental Policy Act (NEPA); the Emergency Planning and Community Right-to-Know Act (EPCRA); the Endangered Species Act (ESA); and, state-equivalent environmental, natural resource, health and safety, and consumer product-related statutes. 

Sam also focuses on developing and implementing corporate climate change-related strategies on the path toward decarbonization and reduction in greenhouse gas emissions. This includes climate mitigation-focused project development and climate-related adaptation concentrated on existing infrastructure and applicable legal frameworks. He is also attentive to identifying the opportunities associated with decarbonization and avoiding short- and long-term unintended consequences. Sam advises clients on corporate social responsibility (CSR) and environmental, social, and corporate governance (ESG) risks, strategies, and foresight on emerging CSR/ESG trends in the US and related foreign non-financial disclosure requirements that impact multinational corporations. Sam also counsels clients on emerging trends associated with environmental justice and human rights, in the context of ESG, but also associated with agency permitting, rulemaking, and enforcement.

For international matters, Sam works to ensure facility and corporate consistency with nation-based laws, international legal frameworks, and industry-specific standards. He assists with development and compliance with facility-specific Environmental and Social Impact Assessments (ESIA) and with advising on consistency with Equator Principles, World Bank established International Finance Corporation (IFC) Performance Standards, and other international environmental, health, safety, and social (EHSS) standards. It is often difficult to assess and calibrate the proper EHSS protocols, especially in developing countries, and he works cross-team with other Hunton attorneys abroad to carefully manage legal, commercial and reputational risks.

Sam frequently organizes, moderates and participates in programs, conferences, and other events for clients and organizations like the ABA Section of Environment, Energy, and Resources and the Environmental Law Institute. He often speaks and writes on trending environmental, energy, climate, natural resource, and sustainability issues and he contributes regularly to the firm’s Nickel Report blog, which focuses on trends and developments in energy and environmental law.

Sam is on the Editorial Board of the ABA’s journal Natural Resources & Environment. He is also a former adjunct professor and guest lecturer, including at the University of San Francisco, where he taught environmental law; Taras Shevchenko National University of Kyiv School of Law in Ukraine, where he lectured on matters related to extractive industries in Europe; Pace University School of Law; Golden Gate University School of Law; and The George Washington University School of Law, where he taught on environmental, energy and land use issues.

Bar Admissions

Education
JD, Pace University School of Law, cum laude, Pace Environmental Law Review, 2007

BA, Political Science and Economics, Michigan State University, 2004

• American Bar Association, Section of Environment, Energy and Natural Resources, Vice Chair, Water Quality and Wetlands Committee
• California Bar Association, Environmental Law Section
• The Bar Association of San Francisco, Environmental Law Section

• 2017 Chambers USA Environment Law Firm of the Year
• US Department of Justice, Environment and Natural Resources Division Commendation, 2014
• EPA Silver Medal for Superior Service, 2015, 2009
• EPA Bronze Medal for Commendable Service, 2008, 2009

• October 2020 Nickel Report Post Summary

  By Samuel Brown, John R. Bobka |November 2020

• Got COVID-19 "Claims": Recent US EPA Enforcement under FIFRA Emphasizes Compliance Demands on Pesticide Product Supply Chains, Especially for Products Claiming to be Effective Against Coronavirus

  By Samuel Brown |November 2020

• Conservation Easements and Land Trusts: Overview, Examples and Their Role in the Development Process, Part II, 17 Envt’l L. in N.Y. 156
• Supreme Court Decision in Hawkes: A Shot Across the Bow, Natural Resources & Environment, ABA Section of Environment, Energy and Resources, Vol. 30, No. 6
• Uncertainty and Exclusions: Implementation of the Final ‘Waters of the United States’ Rule, ABA Section of Environment, Energy, and Resources 23rd Fall Conference
• Vantage Point, American Bar Association’s Natural Resources and Environment Publication, Vol. 35, No. 2
• As Goes Calif. Stormwater, So Goes The Nation’s? Law360
• Calif. High Court Throws Wrench In Cooperative Federalism, Law360
• Conservation Easements and Land Trusts: Overview, Examples and Their Role in the Development Process, Part I, 17 Envt’l L. in N.Y. 133
• Stormwater—The Next Phase, Natural Resources & Environment, ABA Section of Environment, Energy and Resources, Vol. 30, No. 3
• Emerging ESG Frameworks: Global Implications and Local Impacts, American Bar Association
• Introduction to Environmental Law: Cases and Materials on Water Pollution Control, Environmental Law Institute
• New Federal Initiatives Target Food Industry Facilities for Inspection and Enforcement, Food Safety Magazine
• EPA Updates Priorities: First Time In Years, Daily Journal
• Trends in Social and Environmental Responsibility, Natural Resources & Environment, Vol. 33, No. 4
• Ammonia Refrigeration: Increasing Regulatory Requirements, Facility Executive
• New WOTUS Rule Could Have Widespread Impact, The Recorder
• California offshore wind: What's next following the $757 million auction, Renewable Energy World
• A Proposal Off The Rails: California’s Fill and Dredge Policy, The Registry
• A Decarbonized Economy: Risks and Opportunities, Mining the Land, Mining the Sea, Vol. 34, No. 2
• Commentary: EPA Must Approve Primacy for Texas CCS Wells, Hart Energy
• 2022 Marks a Large Step Forward for ESG Disclosure, Retail Industry 2022 Year in Review
• ESG Hot Topics