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Hunton Andrews Kurth LLP

Aaron M. Flynn

Aaron M. Flynn


Hunton Andrews Kurth LLP
D.C., U.S.A.

tel: +1 202 955 1681
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Local Time: Tue. 18:59


Aaron represents companies in major environmental litigation and regulatory matters across the country. His clients include utilities, national trade associations, oil and gas companies, and manufacturers. His practice is focused on reducing and managing his client’s regulatory burdens, particularly under the federal Clean Air Act.

Aaron has helped to resolve complex regulatory matters before the EPA, at the White House, and through his extensive litigation experience before the federal courts. Aaron’s previous roles as a legal advisor to the US Congress and as a lawyer for the White House help him provide insight and practical advice when counseling clients.

As a leader of the firm’s visibility practice, Aaron has been called upon to testify before the US House of Representatives. Aaron has also litigated significant visibility rules before numerous federal courts of appeals, arguing most recently before the Ninth and DC Circuits.

Aaron’s climate change work has involved every significant EPA rulemaking action since the US Supreme Court’s decision in Massachusetts v. EPA. He has, for instance, helped clients find creative solutions in response to the EPA’s Endangerment Finding, its mobile source rules, and the Clean Power Plan for existing electric generating facilities. He has also advised companies in the oil and gas sector on compliance with greenhouse gas reporting requirements and their obligations under the EPA’s methane rules.

Aaron’s practice extends to a number of other areas, including environmental permitting on Tribal lands, litigation in the DC Circuit over fuel regulation, and new source performance standards (NSPS) and hazardous air pollutant (HAP) regulations. He is integral to the firm’s national ambient air quality standards (NAAQS) practice, and has led successful efforts before the DC Circuit and the White House to protect clients from new, unprecedented standards.

Aaron is admitted to practice before the US Supreme Court and the US Courts of Appeals for the Third, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth and DC Circuits. He is also admitted to the US District Court for the District of Columbia.

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

Relevant Experience

  • Advises clients on preparation for the Regional Haze Program’s second implementation period.
  • Represents industry in DC Circuit litigation supporting EPA’s rule allowing compliance with the Cross-State Air Pollution Rule to satisfy regional haze requirements.
  • Devised a Clean Air Act federal implementation plan providing an alternative to costly emission controls for a facility. Defended that plan as an Intervenor-Respondent in litigation involving extensive discussions and negotiations with impacted tribes requiring deep knowledge of rules governing energy development on tribal lands.
  • Developed rulemaking comments opposing greenhouse gas reporting rules for pipelines and related facilities and subsequently challenged EPA's final rule in DC Circuit.
  • Engaged in litigation challenging New Source Performance Standards and National Emissions Standards for Hazardous Air Pollutants for the oil and gas production sector and negotiated with EPA to revise the standards.
  • Represented four western utilities in major challenges to EPA’s visibility rules in the Ninth and Tenth Circuit courts.
  • Led industry efforts challenging the establishment of new secondary NAAQS for nitrogen and sulfur oxides, particulate matter, and ozone.
  • Represented trade associations in preparing comments on EPA’s proposed Federal Plan and Model Trading Rule to implement the Clean Power Plan.
  • Guided interagency regulation of genetically modified organisms as part of the White House Ag-Biotech Working Group.
  • Represented the White House Office of Science and Technology Policy (OSTP) in regulatory review meetings and meetings of the Committee for Foreign Investment in the United States (CFIUS).
  • Advised members and committees of Congress on development of the Energy Policy Act of 2005 and drafted key reports on liquefied natural gas (LNG) regulation, public lands policy, military base closure and property redevelopment (BRAC), and offshore and onshore oil, gas, and renewables development.

Bar Admissions

  • District of Columbia
  • Maryland


BA, The Burnett Honors College, University of Central Florida, English, 2000
Areas of Practice
Professional Career

Significant Accomplishments

  • Represent clients in proceedings before the Environmental Protection Agency regarding greenhouse gas emissions regulation under the Clean Air Act.
  • Advise clients regarding compliance with state and regional greenhouse gas regulatory programs, such as the Regional Greenhouse Gas Initiative and AB 32.
  • Defend clients in federal district and appellate courts in litigation regarding National Ambient Air Quality Standards, New Source Review and Preventive of Significant Deterioration Programs, and pollution related nuisance claims.
  • Provided legal and policy advice to the Science Advisor to the President of the United States.
  • Assisted in the development of a variety of Administration policies, including those addressing climate change, endangered species protections, pesticides and biotechnology derived plants and animals, national security and emergency preparedness communications, federal and commercial aerospace issues, and trade matters involving the International Trade Commission and the Committee on Foreign Investments in the United States.
  • Served as legal advisor to the Members and Committees of the U.S. Congress, analyzing and assisting in the development of numerous pieces of legislation, including the Energy Policy Act of 2005.
  • Worked extensively on LNG import terminal regulation, National Environmental Policy Act litigation, public lands policy, BRAC property redevelopment, federal and state electric utility regulation, and offshore and onshore oil, gas, and renewables development.

Professional Activities and Experience

  • 2017 Chambers USA Environment Law Firm of the Year
  • Listed for Environment: Litigation, Legal 500 United States, 2016
  • Named among Rising Stars for Environmental Law, Law360, 2016
  • Selected as a Top Litigator Under 40, Benchmark Litigation, 2017


  • Litigating Regional Haze: Answers—and Questions—from the Most Recent Court Decisions, Air & Waste Management Association’s EM Magazine
  • Before the Dust Can Settle, New Ozone Standards, Air & Waste Management Association's EM Magazine
  • The Courts Move at Lightning Speed Toward a Decision on the EPA's Clean Power Plan, American Bar Association, Section of Litigation
  • What’s Next for EPA’s Regional Haze Program?, Zephyr Currents
  • The New NAAQS Review Process Begins To Take Shape, EM
  • EPA’s Clean Power Plan Sets the Stage for a Return to the Supreme Court, American Bar Association, Section of Litigation
  • Appellate Court Tells EPA to Think Again about Ambient Standards for Particulate Matter, Air & Waste Management Association’s EM Magazine

WSG's members are independent firms and are not affiliated in the joint practice of professional services. Each member exercises its own individual judgments on all client matters.

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