Dick Penna specializes in environmental law and regulation, an area in which he has practiced in both the public and private sectors for over 30 years. He advises clients in the motor vehicle and related engine production industries regarding the impact of congressional, federal, and state agency requirements on a variety of matters. These include motor vehicle emissions standards, fuel economy regulations, alternative fuels, plant sitings and operations, control of emissions of hazardous air pollutants from surface coating and other manufacturing processes, hazardous waste control, permitting, compliance, and enforcement matters.
Dick provides counsel on the development of emissions standards for air pollutants from motor vehicles (both light and heavy duty), and recreational marine engines and vessels, with a comprehensive understanding of the impact of compliance standards in Title II of the Clean Air Act. On behalf of his clients, he works closely with the Environmental Protection Agency (EPA), the National Highway Traffic Safety Administration (NHTSA), the California Resources Board, and other states that have adopted California’s emissions standards.
Dick played a leading role in the extended consideration of the Clean Air Act throughout the 1980s which resulted in the 1990 amendments. He has been active in numerous rulemaking actions that have resulted from the enactment of that law and has represented clients in enforcement actions brought by the EPA and the state of California.
Dick has served as Vice Chairman of the American Bar Association Air Quality Subcommittee and is a frequent speaker on Clean Air Act and fuel economy programs.
From 1971 to 1977, Dick served in the Office of Enforcement and General Counsel of the EPA. He was involved in the development and litigation of State Implementation Plans for ozone (smog) and carbon monoxide reduction. From November 1978 to June 1981, Dick served as Assistant Director of the National Commission on Air Quality, a congressionally mandated commission that was responsible for recommending modifications to the Clean Air Act.