Frances brings nearly 40 years of environmental experience from both the regulatory and industry perspectives. She represents a broad range of clients before various regulatory entities, including the US Environmental Protection Agency (EPA), California Air Resources Board (CARB), State Lands Commission (SLC) and the local air pollution agencies. Her expertise encompasses rule development, compliance issues, state and federal Clean Air Acts (CAA), the Clean Water Act (CWA), Compensation and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA), multijurisdictional regulatory development, Title V and equipment permitting, credit trading, and global climate change. She represents clients before district hearing boards on variances, Title V alternative operating conditions, and permit appeals. Frances also advises clients planning development projects on permitting and compliance and helps to develop, review and defend California Environmental Quality Act (CEQA) analyses.
In her career at the South Coast Air Quality Management District, Frances advised the District Governing Board and staff on legal authority and obligations under all applicable laws including the state and federal CAA, CEQA, Torts Claims Act, Brown Act, regulatory development, conflicts and contracts law. She worked with senior management to develop district programs, strategies, and policies including Air Quality Management Plans (AQMPs), rules and regulations. She testified on behalf of the District at legislative and regulatory hearings regarding air quality issues. Frances represented the District in the development of state and federal programs to regulate nonroad sources such as locomotives, marine vessels and ground support equipment. Her litigation experience includes initiating and defending the District in state and federal courts, primarily focused on the CAA and CEQA, and representing the Executive Officer in administrative hearings before the District Hearing Board. She also hired and supervised outside counsel in liability matters and CEQA litigation. Frances developed and conducted staff training in enforcement and regulatory development.