Dixon has been with the firm's Environmental Practice Group since 1987 and has extensive experience assisting clients with environmental permitting, compliance, and enforcement issues with particular focus on state and federal air laws, pollution prevention initiatives, and toxics reduction requirements. In Best Lawyers in America's inaugural "Lawyers of the Year" designations, Dixon was named "2012 Portland, Maine Environmental Lawyer of the Year."
Dixon has been involved in hundreds of air quality licensing, regulatory and enforcement activities, representing a wide variety of business and manufacturing interests, including pulp and paper, semi-conductor, forest products, electric utility, leather tanning, textile, food products, petroleum storage and distribution, metal products, landfill gas-to-energy and biomass boilers. He has assisted businesses in over a dozen states with air issues, including, most recently, Clean Air Act PSD and Title V permitting, MACT compliance, EPA PSD/NSR compliance reviews and enforcement efforts, BART requirements, offset certifications, use of alternative fuels and state and federal greenhouse gas requirements. Dixon has served as national environmental counsel for a paper products company with facilities in five states and, for the past 15 years, as counsel to the Maine Pulp and Paper Association's Environmental Committee.
Dixon's work has included assisting clients to obtain PSD/NSR permits, netting out of PSD/NSR, dealing with Federal Land Managers on BART and visibility impact issues, obtaining offsets to satisfy nonattainment new source review requirements, MACT applicability and compliance, obtaining a Clean Air Act Section 182(f) waiver for the northern half of Maine, developing Clean Air Act § 112 Risk Management Plans, release reporting, Title V compliance certifications and defending major enforcement actions brought under federal and state air laws.
Dixon has participated in virtually all State of Maine air quality legislative and regulatory processes since 1987, with special emphasis on those relating to the major overhaul of Maine's air permitting rules in 1987 - 1988 and the Clean Air Act Amendments of 1990 and has been involved in many federal Clean Air Act rulemakings. Dixon has also performed numerous environmental audits and advised clients on a wide range of other environmental law issues, including hazardous waste, asbestos, pollution prevention, land use and chemical safety issues.
Dixon has been involved in numerous administrative and judicial appeals of agency actions. He also engages in a substantial amount of legislative work, primarily legislative issues under consideration by the Maine Joint Standing Committee on Natural Resources and regularly advocates before the Maine Board of Environmental Protection on rulemaking and permitting matters.
Recent Experience
- Biomass heating at engineered wood products facility. Served as lead counsel to a wood products facility in obtaining all required permits and approvals (including approval of NOx offsets for VOCs) for a new manufacturing line and a new biomass-fired central heating unit
- Emission reduction credits for manufacturing facilities. Assisted a Maine mill and a New Hampshire mill to create and certify NOx and VOC emission reduction credits and NOx emission reduction credits, respectively
- Satisfying BART. Assisted six facilities in Maine with Best Available Retrofit Technology (BART)-eligible units to demonstrate existing controls satisfy BART requirements
- MACT compliance. Advised dozens of facilities regarding compliance with MACT standards, including serving as lead counsel to a wood products company to obtain all permits needed to replace wood strand dryers with new low temperature dryers to comply with production-based MACT limits instead of installation of add-on controls
- Addition of co-gen boiler. Assisted Georgia-Pacific Corporation in obtaining permits and approvals for installation of a new, large, multi-fuel, co-generation boiler. Approved fuels include C&D woodchips
- Landfill gas-to-energy. Assisted Pine Tree Landfill obtain necessary permits for construction and operation of 5 MW landfill gas-to-energy facility
- Gas-fired power plant in Indiana. Assisted Acadia Bay LLC in connection with permitting of a 500 MW greenfield gas-fired electrical generation facility in Indiana
- Air emissions compliance. Successfully represented several large manufacturing facilities that underwent extensive PSD/NSR and Refrigerant (CFC, HCFC) compliance reviews by EPA. These reviews began with EPA information requests seeking large amount of information, in some cases dating back to the 1970s, with respect to virtually every capital project at the facilities and detailed review of compliance with Maine's EPA-approved State Implementation Plan regulations and EPA's New Source Performance Standards
Honors & Distinctions
The Best Lawyers in America's 2012 Portland, Maine Environmental Lawyer of the Year
The Best Lawyers in America for environmental law
Chambers USA: America's Leading Business Lawyers for environmental law
New England Super Lawyers for environmental law
Professional Activities
Member, Maine Air Toxics Advisory Committee, 2003-2010
Member, Maine Pollution Prevention Advisory Committee, 1989-1999 (Chair, 1996-99)
Member, Maine Air Quality Advisory Committee, 1992-2008 • Member, Governor's Emissions Banking & Trading Advisory Committee, 1994-96
Member, Governor's Ozone Attainment Stakeholders Advisory Committee, 1993-94
Member, Maine DEP Toxics Use Reduction Act Stakeholders Advisory Committee, 2009-2011
Publications
Dixon has written and lectured extensively on federal and state air quality control regulations. He is a co-author of:
- New England Regional published in American Bar Association, Natural Resources Section newsletters
- "The Maine Air Permitting Handbook," 1996
- "Environmental Law in Maine," (annual) 1991-
- "Hazardous Waste in Maine," National Business Institute, 1990-1992;
- "Chemical Safety & Hazardous Waste - New Issues in Maine," 1994 & 1996, The Cambridge Institute
- "Turning on the Lights - Reporting Under SARA Title III Illuminates Tort and Environmental Liabilities," The Environmental Professional, 1989