512.370.2823 Direct
512.370.2850 Fax
San Antonio (secondary office)
210.277.6800 Direct
210.277.6810 Fax

Chris Pepper is a member of Winstead’s Energy & Environmental Practice Group. Chris’ practice focuses on air quality and environmental matters relating to laws and regulatory programs established by the Texas Commission on Environmental Quality (TCEQ) and US Environmental Protection Agency (EPA).

Chris is recognized throughout Texas for his experience in guiding clients through all stages of the environmental permitting process, including the initial application, technical review, and public notice and meeting procedures. He also represents clients in contested proceedings before the State Office of Administrative Hearings (SOAH).

A registered patent attorney, Chris holds a Master of Science in Environmental Toxicology and brings a unique technical perspective to client matters. Prior to his private practice, Chris served as an in-house attorney at the Air and Water Quality Sections of the Offices of Legal Services at the TCEQ. He also worked as a senior research associate at the Institute of Environmental and Human Health in Lubbock, Texas, where he was a member of the Vector-borne Zoonoses Laboratory.

Unique Lawyer Experience

  • Completed more than 65 audits of quarries, sand plants and ready-mix facilities
  • Completed more than 50 audits, site inspections, and regulatory reviews of fertilizer facilities and ag retail centers (SIC 5191)
  • Edwards Aquifer Water Pollution Abatement Plans (Chapter 213)
  • Emission Banking and Trading Programs 
  • Environmental Enforcement and Compliance History Reviews 
  • Environmental and regulatory policies implemented by EPA, Comptroller’s Office, Texas Department of Transportation (TXDOT), Texas Department of Agriculture (TDA), Texas Department of Motor Vehicles (DMV) and the TCEQ
  • Texas and US EPA Self-Audit and Self Disclosure Policies
  • Serve as General Counsel to Texas Aggregates & Concrete Association
  • Oversize-overweight (OS/OW) permits for commercial fleet vehicles 
  • TRI and Tier II Chemical Inventory Reporting

Representative Experience

Air Permits

  • Represented a precast concrete company located in Harris County, Texas, in a contested hearing for an air quality permit for a specialty mix batch plant
  • Represented an aggregates company located in Comal County, Texas, through all phases of the HB801 permit application and public participation process for a contested New Source Review (NSR) Permit
  • Represented a steel pipe manufacturing company in a contested air quality permit application for a new pipe mill and associated electric arc furnace in San Patricio County, Texas
  • Assists multiple rock crushing, sand mining, concrete batch plants, feed mills and fertilizer warehouses with air quality permit amendments, permit alterations, and permit reaffirmations
  • Represents industrial manufacturing facility subject to TRI reporting (Toxic Release Inventory) for anhydrous ammonia

Environmental Audits

  • Performed on-site environmental audits at steel fabrication facilities, fertilizer warehouses, and concrete batch plants throughout Texas using Texas’ Environmental Health and Safety Audit Privilege Act
  • Assisted clients with verifying environmental compliance for new acquisitions by performing environmental audits of plant production records, pollution control equipment, and various TPDES, PSD, NSR and PBR recordkeeping requirements
  • Engaged in a variety of noticed self-audits at the TCEQ for rock, sand and mineral extraction facilities pursuant to House Bill 571, which is a new registration requirement for all of Texas’ aggregate production operations (APOs) under 30 Tex. Admin. Code Chapter 342

Environmental Litigation

  • Assisted clients with comprehensive air quality litigation strategies, including communication techniques, on-site environmental risk and exposure assessments, and with dust and particulate matter air quality studies in Texas and New Mexico
  • Represented clients in the agriculture and aggregates industries with contested SOAH hearings that are subject to the Texas Rules of Civil Procedure and the Texas Rules of Evidence
  • Represent client in nuisance and CERCLA matters

Emergency Response

  • Responded to spills, fire, explosions and emission events at various manufacturing, chemical, and aggregate facilities to verify compliance with TCEQ’s Emission Event Reporting Rules in 30 Texas Administrative Code Chapter 101 and with TCEQ’s Spill Prevention and Control Rules in 30 Texas Administrative Code Chapter 327
  • Assists clients with 24-hour reporting obligations under the STEERS electronic reporting system

Public Outreach

  • Represents clients at TCEQ Public Meetings, Informational Meetings, and Commission Agendas associated with TCEQ air quality rules, TCEQ PST regulations, SIP ozone planning, and new TCEQ rulemaking activities such as the standard air quality permits for the agriculture and concrete production industries
  • Assists clients with developing effective public communication strategies with elected officials, regional economic development office, and with environmental advocacy groups

Search Tips:

You may use the wildcard symbol (*) as a root expander.  A search for "anti*" will find not only "anti", but also "anti-trust", "antique", etc.

Entering two terms together in a search field will behave as though an "OR" is being used.  For example, entering "Antique Motorcars" as a Client Name search will find results with either word in the Client Name.


AND and OR may be used in a search.  Note: they must be capitalized, e.g., "Project AND Finance." 

The + and - sign operators may be used.  The + sign indicates that the term immediately following is required, while the - sign indicates to omit results that contain that term. E.g., "+real -estate" says results must have "real" but not "estate".

To perform an exact phrase search, surround your search phrase with quotation marks.  For example, "Project Finance".

Searches are not case sensitive.

back to top