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About Jeff

Jeff Holmstead, former assistant administrator of the United States Environmental Protection Agency for Air and Radiation, is one of the nation’s leading climate change lawyers as recognized by Chambers USA (2008-2021) and heads the Environmental Strategies Group at Bracewell. The Environmental Strategies Group is a multi-disciplinary group that includes environmental and energy attorneys, public policy advocates and strategic communications experts – most of whom have had high-level government experience. Under Jeff’s leadership, they work together on a daily basis to advise and defend companies and business groups confronting major environmental and energy-development challenges, both domestically and globally.

From his time in both the government and the private sector, Jeff is very familiar with the environmental and energy challenges facing the business community. He advises clients dealing with an increasingly complex regulatory, legal and public relations landscape, drawing on his experience in policy development, administrative and legislative advocacy, litigation and strategic communications. He has worked with clients in a number of industries on issues related to climate change, Clean Air Act policy and enforcement, and energy policy — including the development of new coal-fired power plants, refineries, renewable energy sources, and electric transmission infrastructure.

Jeff headed the EPA’s Office of Air and Radiation from 2001 to 2005, longer than anyone in EPA history. During his tenure, he was the architect of several of the agency’s most important initiatives, including the Clean Air Interstate Rule, the Clean Air Diesel Rule, the Mercury Rule for power plants and the reform of the New Source Review program. He also oversaw the development of the Bush Administration’s Clear Skies Legislation and key parts of its Global Climate Change Initiative. Between 1989 and 1993, Jeff served on the White House Staff as Associate Counsel to former President George H.W. Bush. In that capacity, he was involved in the passage of the Clean Air Act Amendments of 1990 and the key steps taken to implement those amendments. From 1987 to 1988, he served as a law clerk to Judge Douglas H. Ginsburg on the U.S. Court of Appeals for the District of Columbia.

His understanding of the EPA is unparalleled. His collaborative approach to issues is fantastic.” “He’s brilliant...he’s widely respected across the industry.
Chambers USA, 2021


Publications and Speeches

Keynote speaker, “Plan for Growth and Sustain Compliance in an Uncertain Climate”, Environmental Resource Management’s Air Quality Roundtable for Natural Gas Midstream Industry, September 2019

Keynote speaker, “Sea Change? Energy and Environmental Policy Under Trump,” Southern Gas Association Management Conference, April 27, 2017.
Moderator, “All Trumped Up: The First 100 Days and Beyond,” Gulf Coast Power Association Spring Conference & Exhibition, April 19, 2017.

Panelist, “Clearing the Air on the Status of Significant Air Regulations,” American Bar Association Section of Environment, Energy, and Resources Spring Meeting, March 31, 2017.

Panelist, “The Evolving Southeast Energy & Environmental Policy Landscape,” Energy and Environmental Policy Landscape: Charting the Course for the Southeast Electricity Sector, hosted by Duke University's Nicholas Institute for Environmental Policy Solutions, February 15, 2017.



Yale Law School,
Brigham Young University,
Bachelor of Arts
summa cum laude

Bar Admissions

District of Columbia



U.S. firm on withdrawing from Paris Accord

September 18, 2017
CBC Television Network Online

Trump riles Dems with pick for powerful EPA job

September 10, 2017
Hill Online, The

Trump's Team Is Split Over the Paris Agreement

April 18, 2017
Scientific American Online

Trump to Require Two Rules Be Killed for Each New One Issued

January 30, 2017
Bloomberg News - Washington Bureau

EPA’s New Source Review Program: Time for Reform?

January 9, 2017
Environmental Law Reporter, The

A former air chief's warning about the EPA

April 17, 2016
Washington Examiner Online

Green billionaire warns GOP not to hold up Obama court pick

February 17, 2016
Washington Examiner Online

The EPA's Secret Staff

December 18, 2015
Wall Street Journal Online, The

The GOP's quick fix on climate change

September 28, 2015
Washington Examiner Online

Delaying Clean Power Plan unacceptable

August 3, 2015
Sentinel republic

Court Gives Obama a Climate Change Win

June 9, 2015
New York Times - Washington Bureau, The

Litigation Awaits New EPA Emissions Rules

March 22, 2015
Wall Street Journal Online, The

U.S. Clean Power Rules Delayed

January 8, 2015
Scientific American Online

EPA may miss deadline on climate rule

December 10, 2014

What the U.S. Needs to Do to Meet New Climate Commitment

November 13, 2014
Scientific American Online

The coming climate onslaught

November 11, 2014

Supreme Court weighs issue of cross-state air pollution

December 7, 2013
USA Today - Washington Bureau

Businesses Wary as Obama Picks Get Edge in Senate Rules

November 22, 2013
Bloomberg Businessweek Online

CQ News

October 15, 2013
CQ News

Obama's climate plan aims straight at coal

June 30, 2013
Salt Lake Tribune Online

Obama climate strategy represents piecemeal approach

June 25, 2013
Washington Post Online, The

The social cost of carbon is on the rise

June 7, 2013
Denver Post Online, The

Log-jam in agency confirmations

May 22, 2013
Nature - Online

E.P.A. Will Delay Rule Limiting Carbon Emissions at New Power Plants

April 12, 2013
New York Times - Washington Bureau, The

Major changes for emissions?

March 19, 2013
Electric Light & Power Online

Why the EPA might delay its carbon rules for power plants

March 18, 2013
Washington Post Online, The

03.10.13 Looking Closer at Ernest Moniz, Gina McCarthy

March 15, 2013
Platts Energy Week TV - Online



FAQ: Reversal of "Once In Always In"

March 6, 2018

On February 8, 2018, ERM and Bracewell presented a webinar that took a look at the legal and technical issues related to EPA’s January 25th memo reversing the long standing “Once In Always In” policy. With this policy change, facilities that are able to be permitted as “area sources” under Section 112 of the Clean Air Act will generally be able to reduce the burden of paperwork, monitoring, recordkeeping and reporting requirements and comply with air quality requirements with greater certainty and less headache.

Click here to view a recording of the webinar.

Holmstead Testimony on NSR Reform

February 14, 2018

 On February 14, Environmental Strategies Partner Jeff Holmstead testified before the House Committee on Energy and Commerce on the need to reform EPA’s New Source Review (NSR) program. As the former head of EPA’s Air Office, Holmstead argues that thoughtful reform can preserve the benefits of the NSR program while substantially reducing the burden that it imposes on U.S. industry. 

EPA Issues Proposal to Repeal the Clean Power Plan

October 16, 2017
Energy Legal Blog®

On October 10, 2017, EPA Administrator Scott Pruitt formally announced that he had signed a proposed rule to repeal the Obama EPA’s controversial Clean Power Plan (CPP). This proposal is the first formal step toward repealing the CPP and the beginning of a public process that the Trump Administration will use to determine whether...

President Trump Signs Executive Order “Promoting Energy Independence and Economic Growth”

March 29, 2017
Energy Legal Blog®

On March 28, President Donald Trump signed an Executive Order titled “ Promoting Energy Independence and Economic Growth .” Touted by the administration as both “protecting the environment and promoting [the] economy,” [1] the Order aims to “promote clean...

White House: Oil & Gas Industry Must Cut Methane Emissions By 40-45%

January 14, 2015

On January 14, 2015, the White House announced that it would for the first time directly regulate methane emissions from the oil and gas industry. By choosing to regulate methane directly rather than regulating VOCs, EPA may be seeking to create a legal basis (and perhaps even a legal obligation) to regulate methane emissions from existing oil and gas operations in the future. According to the announcement, the oil and gas sector will need to reduce its methane emissions by 40-45% from 2012 emission levels by 2025. Although this announcement did not indicate how industry must achieve these...

9th Circuit Appeals Court: Clean Air Act Permits Must Address Latest EPA Requirements

August 13, 2014

On August 12, 2014, the 9th Circuit Court of Appeals overturned a Prevention of Significant Deterioration (PSD) permit issued under the Clean Air Act (CAA) by EPA to the Avenal Power Center. Sierra Club v. EPA, No. 11-73342 (9th Cir. Aug. 12, 2014). The PSD permit authorized the construction of a 600 MW natural gas-fired plant located in California's San Joaquin Valley. The plant was required to install state-of-the-art pollution controls for all traditionally regulated pollutants, such as nitrogen oxides, particulate matter, and carbon monoxide. The Court vacated the PSD permit because it...

Supreme Court Limits EPA's GHG Permitting Authority and Creates Questions Regarding Implementation

June 30, 2014

On Monday, June 23, the U.S. Supreme Court issued its long awaited decision in UARG v. EPA , the case that questioned EPA's authority to require stationary sources to obtain Prevention of Significant Deterioration (PSD) and Title V air permits for greenhouse gases (GHGs). Specifically, the Court considered: (1) whether a stationary source can be required to obtain a PSD or Title V air permit based solely on its potential to emit GHGs and (2) whether sources that have to obtain PSD and Title V permits based on their potential to emit traditional criteria pollutants (so called "anyway sources...

EPA Proposes Rule Seeking to Curb GHG Emissions and Dampen U.S. Appetite for Electricity

June 4, 2014

On June 2, 2014, EPA issued a proposed rule to control carbon dioxide emissions from existing coal-fired power plants. In its public outreach, EPA presents the rule as requiring a 30% reduction in carbon emissions by 2030 from the baseline year 2005. It is true that the rule would result in CO2 emissions that are 30% lower than in 2005, but the actual state-by-state emission reduction requirements are based on a 2012 baseline, which may disadvantage certain states or companies that made significant CO2 reductions before that year. The proposal establishes GHG emission targets for each State (...



Chambers USA
Nationwide Climate Change, 2010 - 2021; District of Columbia Environment, 2008 - 2021
The Legal 500 United States
Environment: Litigation, 2012, 2016 - 2021; Environment: Regulatory, 2017 - 2021; Environment: Transactional, 2017 - 2021; Government Relations, 2019 - 2020; Energy Litigation: Conventional Power, 2017 - 2018
ALM Media Properties, LLC
National Law Journal
Energy & Environmental Trailblazer, 2016
BL Rankings
Best Lawyers
Environmental Law, 2008 - 2022; Litigation - Environmental, 2020 - 2022
Lawdragon Leading 500 Lawyers in America