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Full Service Law Firm | Michael Best & Friedrich LLP

Specializing in the Intersection of Business &amp; Government

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Drawing on over 30 years of experience spanning nearly every major industrial category, Todd guides leadership teams in translating dense regulatory requirements into practical, defensible compliance plans that protect operations and reduce enforcement risk. This includes helping clients navigate the intersection of environmental law, engineering, policy, and business realities, with a particular focus on Clean Air Act strategy, permitting, compliance, and enforcement defense. Todd helps companies and public entities. Clients call Todd when the stakes are high: complex permitting and applicability questions (including NSR/PSD and Title V), multi-agency investigations, controversial siting projects, citizen suits, novel enforcement theories, and rulemakings that can reshape an entire sector. 

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Todd is also&nbsp;recognized for precedent-setting Clean Air Act and administrative-law work at the state and federal appellate levels. He has represented industry coalitions and public entities in significant challenges involving interstate air transport and other EPA programs, and he has defended major enforcement matters, including cases that helped define the limits of governmental Clean Air Act enforcement authority. In 2016, Todd was among the counsel team representing state interests that obtained a U.S. Supreme Court stay of the federal Clean Power Plan—a first-of-its-kind stay at that procedural stage. In addition to air, Todd advises clients on PFAS and emerging contaminants, remediation and cost recovery, and environmental risk allocation in complex matters where technical strategy and legal positioning must move together.

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Todd is a Fellow of the American College of Environmental Lawyers and the American Bar Foundation, and he is consistently recognized by leading legal directories and peer-reviewed rankings, including Chambers USA (Band 1) and The Best Lawyers in America (including multiple “Lawyer of the Year” recognitions). He is also a co-author of key Wisconsin environmental treatises, including editions of the Wisconsin Environmental Law Handbook and American Bar Association publications.

Todd serves on the Wisconsin DNR Air Management Study Group and is a frequent speaker on Clean Air Act and regulatory enforcement developments.

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Clean Air Act &amp; Air Quality

Successful representation of Wisconsin industry and utility interests in the NOx SIP Call. State of Michigan, et al. v. Environmental Protection Agency, 213 F.D. 663 (D.C. Cir. 2000).

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Successful representation of an industrial coalition challenging the Cross‑State Air Pollution Rule. EME Homer City Generation v. EPA, Case No. 11‑1315, et al. (D.C. Cir. Aug. 21, 2012).

Represented a trade organization in the defense of EPA’s decision approving New Source Review Reforms into the Wisconsin State Implementation Plan. Natural Resources Defense Council and Sierra Club v. Jackson, Nos. 09‑1405 &amp; 10‑2123 (7th Cir. June 6, 2011).

Defense of various clients in matters involving EPA’s new source review enforcement initiative targeting the utility and petroleum refining industries. Experience with settling cases with non‑government environmental organizations, EPA, and state agencies.

Supporting coalition of businesses and local chambers of commerce seeking to mitigate the adverse impacts to southeast Wisconsin caused by ozone pollution attributable to upwind states.

Special counsel to Box Elder County Utah pursuant to a contract with the Utah Department of Environmental Quality and Utah Division of Air Quality. Provided services to support the possible removal of Box Elder County from the Salt Lake City PM2.5 Nonattainment Area and maintaining attainment thereafter.

Represented numerous clients in responding to information requests from state and federal regulators, including EPA requests for information under Section 114 of the Clean Air Act.

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Climate Change &amp; Energy Regulation

Represented the Mississippi Public Service Commission in coalition efforts that obtained a stay of the federal Clean Power Plan from the U.S. Supreme Court in a 5‑4 decision. The Clean Power Plan sets the first national carbon emission limits for U.S. electric power plants. The decision marked the first time a U.S. Supreme Court has ever granted such a motion in its history.

Represented various industrial and utility clients in evaluating and implementing repowering initiatives for thermal and electric generating assets.

Represented alternative energy facilities and equipment manufacturers (ethanol, biodiesel, solar, bio‑refining, biomass and gasification) in permitting and enforcement matters.

Environmental Enforcement &amp; Compliance

Represented a petroleum refinery in a multimedia enforcement action stemming from a National Enforcement Investigations Center inspection. The enforcement case was jointly prosecuted by the State of Wisconsin and the Environmental Protection Agency. United States v. Murphy Oil USA, Inc., 143 F. Supp. 2d 1054 (W.D. Wis. 2001).

Represented clients in compiling and drafting comments on state and federal environmental regulatory initiatives.

Special counsel to the State of Wisconsin defending the Department of Administration in environmental citizen suit and permitting matters related to the state’s heating plant fleet.

Clean Water Act &amp; Water Infrastructure

Successful defense of multiple legal challenges to local and state approvals issued to a regional warehouse and distribution center in Oconomowoc, Wisconsin. One such challenge involved a Clean Water Act citizen suit action. Village of Oconomowoc v. Dayton Hudson Corporation, et al., 24 F.3d 962 (7th Cir. 1994).

Represented a coalition of six municipalities that border the city of Milwaukee challenging the allocation of $2.3 billion in capital costs expended by the Milwaukee Metropolitan Sewerage District in upgrading the sewer system that currently serves southeastern Wisconsin.

Contaminated Sites &amp; CERCLA

Represented a manufacturing entity in multi‑party cost recovery litigation concerning property contaminated with polychlorinated biphenyls. Raytheon Company v. McGraw‑Edison Company, 979 F. Supp. 858 (E.D. Wis. 1997).

Agriculture &amp; Siting

Represented a large dairy operation (over 6,000 head) in the siting of a facility expansion. This included defending against novel citizen suit arguments that the dairy was subject to Clean Air Act permitting requirements.

Todd E. Palmer

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Legal Bites: Q1 2026 Edition

Proposed “Fair Air Standards Act” Would Ease Nonattainment Burdens for Southeast Wisconsin

Microplastics Formally Enter EPA’s Regulatory Radar

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Insights

Legal Bites: Q1 2026 Edition

Proposed “Fair Air Standards Act” Would Ease Nonattainment Burdens for Southeast Wisconsin

Microplastics Formally Enter EPA’s Regulatory Radar

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