Clarissa Anne Howley Mills
Partner
Overview
Clarissa Howley Mills is an environmental attorney in Holland & Knight's Dallas office. Ms. Mills focuses her practice on environmental regulatory counseling, enforcement defense, incident and crisis management, environmental due diligence and advising on environmental matters in corporate and real estate transactions. With experience advising clients under nearly every major federal environmental statute and regulatory program, Ms. Mills assists clients developing big-picture strategies on some of the most complex environmental issues facing regulated entities today.
Drawing on nearly a decade of leadership experience at the U.S. Environmental Protection Agency (EPA), Ms. Mills helps clients navigate evolving regulatory frameworks, emergency response incidents, enforcement actions, agency investigations and permitting with a pragmatic, business‑focused approach. She is known for bringing deep institutional knowledge of agency processes and enforcement priorities to help clients anticipate regulatory risk, engage effectively with regulators and reach efficient, durable resolutions.
During her time at EPA, Ms. Mills served as deputy regional counsel for EPA Region 6. In that role, she managed one of the agency's largest regional legal offices and advised senior officials on high‑stakes emergency response and remediation matters, permitting decisions, and federal and state oversight issues across a five‑state region and dozens of federally recognized Tribes. She provided counsel under key environmental statutes, including the Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Safe Drinking Water Act (SDWA), Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Toxic Substances Control Act (TSCA) and related regulations.
Prior to her deputy role, Ms. Mills served as the lead senior counsel for chemical enforcement actions, where she acted as a national subject matter expert on investigations under the Chemical Accident Prevention regulations, as well as pesticide, toxic chemicals and hazardous waste programs. In that capacity, she led investigations of significant industrial incidents and helped secure settlements totaling tens of millions of dollars in penalties, along with extensive environmental compliance commitments. Accordingly, Ms. Mills is well suited to advise clients in resolving governmental investigations and enforcement actions, including negotiating penalty and compliance orders.
Prior to joining Holland & Knight, Ms. Mills worked for a global law firm in Dallas in its environmental practice group. While there, she counseled clients on environmental regulatory compliance, enforcement defense, litigation, due diligence and transactional matters.
Representative Experience
- Advised multiple clients on post-acquisition environmental compliance obligations, including hazardous waste reporting, pesticide production reporting and permitting
- Counseled pesticide production companies on registration, labeling and reporting requirements, including comprehensive product line label and related marketing material auditing and corrective action
- Advised numerous international clients on the rules and reporting requirements associated with the import and export of chemicals, pesticides and hazardous waste
- Assisted multiple clients in authoring corporate environmental policies as well as evaluating environmental and climate related risks for and authoring U.S. Securities and Exchange Commission (SEC) filings
- Counseled multiple clients in responding to requests for information from the U.S. Environmental Protection Agency (EPA) and state environmental agencies related to allegations of potential non-compliance with environmental laws and regulations, including under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Emergency Planning and Community Right-to-Know Act (EPCRA) and Clean Air Act (CAA)
- Advised multiple manufacturing clients in emergency industrial accidents resulting in environmental spills and releases, including counseling on required federal and state government reporting, interactions with federal, state and local response agencies, responding to requests for information, navigating responding to community concerns and inquiries, and preparing for potential reputational harm and litigation risk
- Represented an exploration oil and gas company in defending claims of non-compliance with underground injection control (UIC) requirements under the Safe Drinking Water Act by EPA
- Advised a national company in responding to a wide-scale CWA stormwater permitting investigation by EPA
- Represented a chemical storage company in resolving General Duty Clause claims under Section 112(r) of the CAA by EPA, including the negotiation of a Consent Agreement and Final Order
- Counseled a client through conducting an environmental audit and obtaining benefits available under federal compliance audit policies
- Represented clients in negotiating the terms of federal Consent Decrees with the U.S. Department of Justice (DOJ), EPA and relevant state agencies, including for penalties and compliance actions
- Resolved Clean Water Act claims brought under Section 505 against a manufacturing client by an environmental non-governmental organization (NGO)
- Provided support related to environmental expert evaluations for litigation teams defending international gasoline manufactures in allegations of chemical exposure
- Counseled multiple real estate investment clients in evaluating potential environmental risks and negotiating environmental terms in purchase agreements
- Assisted in environmental due diligence review for multiple merger and acquisition transactions, and negotiating environmental terms with corporate teams
- Counseled in evaluating potential risk and negotiating environmental indemnity agreements associated with finance and commercial real estate transactions for numerous clients
Credentials
- University of Kansas School of Law, J.D.
- Kansas State University, B.A., English, Minor in Women's Studies
- Texas
- Dallas Bar Association (DBA), Environmental Law Section, Chair, 2026
- DBA, WE LEAD Program, Graduate, 2023
- State Bar of Texas, Environmental and Natural Resources Law Section
- American Bar Association (ABA), Section of Environment, Energy and Resources (SEER)
- Best Lawyers in Dallas, D Magazine, Environmental Law, 2026
- Environment and Natural Resources Division (ENRD) Award for Excellence, U.S. Department of Justice, 2023-2024