Locke Lord LLP

600 Travis
Houston, TX 77002

d. (713) 226-1402





Houston I

Gerald Pels


Gerry Pels, Chair of the Firm-wide Environmental Section - Energy and Industry, has been one of the leaders of the Texas environmental legal community for over 30 years. His diverse practice focuses on the areas of environmental compliance, counseling, and litigation. During his career, Gerry has consistently led teams working on cutting edge matters of environmental law, including resolving the well-known Cooper v. Aviall litigation and arguing Clean Air Act issues before the 5th Circuit in litigation involving the Texas SIP. Gerry has been consistently recognized in Chambers USA since 2004 as well as in The Best Lawyers in America for Environmental Law. He was also an adjunct law professor for seven years teaching both environmental law and an advanced RCRA seminar.

Gerry's wide range of experience includes agency negotiations, assessing and counseling air, water, stormwater, and waste permit compliance, representing clients at contested permit, enforcement, and other hearings. He has also provided comprehensive assistance and representation to potentially responsible parties and steering committees at both state and federal Superfund sites. He has been called upon to lead internal environmental investigations and provide strategic guidance on corporate compliance policies, sustainability initiatives, stakeholder involvement, and community relations planning, as well as corporate risk assessment and mitigation. Regarding Gerry, Chambers has quoted an opposing counsel as saying, “You just pray you don’t get him opposite you.”

Representative Experience

  • Representing a major manufacturer in connection with environmental indemnity claims involving response at over 100 facilities in the United States and abroad. The matter settled after three weeks of trial.

  • Evaluating, negotiating, and developing risk management strategies related to facility acquisitions and divestitures including development of manuscripted insurance products, utilization of audit privilege and immunity programs, and other means to address environmental responsibility.

  • Representing a hazardous waste management facility in connection with re-permitting its solvent recycling and fuels blending units to address VOC emissions on a non-speciated basis and defending related enforcement actions.

  • Representing a major energy company in connection with focused due diligence including NSR permitting analyses of proposed and existing source modifications and other air emissions compliance matters associated with potential refinery acquisitions.

  • Representing a Fortune 500 manufacturer in connection with potential emissions aggregation at plants in close proximity to one another and development of a strategy to avert major source thresholds.

  • Representing a major manufacturer in connection with air permitting related to a proposed manufacturing facility including development of an approach to synthetically limit emissions and rely upon permits by rule for its sources so that the facility could timely open and fulfill contractual requirements. Prior counsel and consultants had embarked upon a permitting approach that resulted in the necessity of timely public notice, comment and a threat of challenge to permit issuance.

  • Representation of industrial concerns in Title V permitting throughout the United States including Texas, Louisiana, Georgia, Illinois, Indiana, and Pennsylvania.

  • Arguing before the Fifth Circuit a defense of the Houston-Galveston SIP against claims brought by various parties, including environmental activist groups.

  • Providing corporate level strategic planning to address environmental initiatives including air emissions management and reductions, sustainability, and climate change risk assessment and preparedness.

  • Developing stakeholder analyses to develop and refine facility acquisition and permitting strategies.

  • Siting and permitting industrial and energy facilities including solid and hazardous waste management facilities, manufacturing plants, power plants, and renewable energy facilities, including wind farms, biodiesel plants, biomass facilities, and others.

  • Assessing compliance options and providing counseling for all regulatory environmental media programs. 

  • Defending enforcement actions and representing clients at permit and other administrative hearings.

  • Providing comprehensive representation of potentially responsible parties and steering committees at both state and federal Superfund sites.

  • Strategic planning concerning acquisition and agency negotiation for redevelopment of brownfields and Superfund facilities.

  • Assisting in the review and preparation of remedial work plans and investigations, feasibility studies, and community relations plans to both establish an evidentiary basis to support litigation and to defend approaches to response.

  • Negotiating agreed orders to, among other things, resolve enforcement actions, conduct remedial investigations, feasibility studies, and other regulatory actions.

Professional History

  • Partner, Locke Lord LLP

  • Chair, Locke Lord Environmental Section – Energy and Industrial

  • Partner, Sutherland Asbill & Brennan LLP

  • Adjunct Professor, Environmental Law and Advanced Hazardous Waste Seminar, South Texas College of Law, Houston (1991 - 1997)

Professional Affiliations and Recognitions

  • Named to 2017 Top 100 Registry Business Leaders & Professionals

  • Named to Houstonia Magazine Top Environmental Lawyers (2013-2015)

  • Named, America's Leading Business Lawyers (Environmental), Chambers & Partners Publishing (2004-2019)

  • Named, The Best Lawyers in America, Environmental, Woodward White Publishers, Inc. (2006-Present)

  • Member, The Lawyers of Distinction (2019)

  • Member, Association of Chemical Industry of Texas

  • Member, Houston Bar Association, Environmental Section

  • Member, Greater Houston Partnership

  • Member, American Bar Association, Natural Resources and Administrative Law and Regulatory Practice Sections & Cleantech and Climate Change Committee

  • Member, Texas Bar Association, Environmental and Natural Resources Section

  • Member, Houston Bar Association, Environmental Section

  • Member, Petro-Safe Planning Committee (1994 - 1995)

  • Named, Texas Super Lawyer (2007-2011, 2013)

  • Named, Texas Super Lawyer, Corporate Counsel Edition (2008)

  • Named, Leading Environmental Lawyers, H Magazine

  • Named, Rue Ratings' Best Attorneys of America (2015)

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800 S. Figueroa, Suite 925

Los Angeles, CA 90017



(213) 712-9080