Paul Freeman

Partner

Overview

Paul Freeman is a partner in Crowell & Moring’s New York office and a member of the firm’s Environment and Natural Resources and Government Contracts groups. He brings two decades of diverse experience advising clients in the energy, maritime, and aerospace and defense industries on a range of issues, with a primary emphasis on matters involving enforcement defense, litigation, and risk management.

Paul routinely advises clients in response to investigations by, or inquiries from, a range of regulators, primarily the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (DOJ), and also including the U.S. Securities and Exchange Commission, the Internal Revenue Service, the U.S. Department of Defense Inspector General, the Federal Bureau of Investigation, the U.S. Commodity Futures Trading Commission, and state attorneys general.
 
Over the past several years Paul has represented a wide range of fuel suppliers, commodities traders, and other market participants in matters arising under the federal Renewable Fuel Standard (RFS) program, including the RFS Quality Assurance Program and the ongoing representation of clients currently confronting enforcement by EPA and DOJ under the RFS regime. 

Extending his risk management and investigations practice across multiple industrial sectors, Paul also counsels Fortune 50 defense contractors on compliance with aspects of the Federal Acquisition Regulation (FAR), including the mandatory disclosure rule, and he routinely conducts internal investigations involving supply chain risks, ethics, quality systems, contract compliance, and potential false claims.

Prior to joining Crowell & Moring, Paul was counsel at a major global law firm.

Career & Education

    • Environmental Protection Agency
      Office of General Counsel Honors Program, 1997
    • Environmental Protection Agency
      Office of General Counsel Honors Program, 1997
    • Vermont Law School, M.S.E.L., cum laude, 2001
    • Vermont Law School, J.D., 1998
    • St. Lawrence University, B.A., cum laude, 1995
    • Vermont Law School, M.S.E.L., cum laude, 2001
    • Vermont Law School, J.D., 1998
    • St. Lawrence University, B.A., cum laude, 1995
    • New York
    • Connecticut
    • District of Columbia
    • U.S. District Court for the Eastern District of New York
    • U.S. District Court for the Southern District of New York
    • U.S. District Court for the District of Connecticut
    • New York
    • Connecticut
    • District of Columbia
    • U.S. District Court for the Eastern District of New York
    • U.S. District Court for the Southern District of New York
    • U.S. District Court for the District of Connecticut

Paul's Insights

Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....

Recognition

  • Law360: Practice Group of the Year – Government Contracts, 2019

Paul's Insights

Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....

Paul's Insights

Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....