Jorge L. San Miguel

Jorge’s professional experience includes:

• Represented a creditor on Puerto Rico legislative developments, fiscal and restructuring plan matters, local economic developments, and US Congress involvement pertaining to Puerto Rico’s fiscal and economic crisis. Invited to testify before the US Congress’ Subcommittee on Energy and Mineral Resources, House Committee of Natural Resources, on January 2016, on the matter of “Exploring Energy Challenges and Opportunities Facing Puerto Rico.” Collaborated with congressional representatives in matters pertaining to the Puerto Rico Oversight Management and Economic Stability Act of June 30, 2016 (PROMESA).
• Represented Amgen Manufacturing Ltd. on its manufacturing site energy master plan, including energy sourcing from onsite/collocated LNG, photovoltaic, and waste-to-energy production. Project sought to leverage greenhouse gas reduction policies. Negotiated terms and conditions for WTE facility and a development schedule, as well as interconnection with the PREPA.
• Represented private entity on federal and local Safe Drinking Water Act sampling, reporting, and compliance issues.
• Worked with landowner on long-term lease negotiations for utility scale 57 MW solar project (Yarotek) in Isabela, Puerto Rico.
• Counseled and advised a Resource Recovery/WTE Facility proponent on pre-development and development efforts to permit and license a $750 million, 80 MW, base load energy generating facility using municipal solid waste and related refuse. Subject matter issues involved power purchase and operation agreements with PREPA, local land use and environmental permitting, federal permitting before the US EPA and US COE, an environmental impact study drafting and approval process, landfill compliance issues, municipal solid waste agreement, community outreach, strategic communications, and government affairs.
• Represented wind and solar renewable energy proponents in PPOA before the PREPA, other PPOA holders, various government agencies (PRIDCO, PR Land Authority, municipalities) on siting consultation matters and related permitting and compliance.
• Represented Siemens Energy, Inc. on electric utility restructuring scenarios, LNG combined cycle power plant evaluation, planning and pre-development matters, power plant sizing, fuel options, location, community, and related issues. Negotiated related agreements with joint venture partner (Puma Energy Caribe, LLC) and prepared a response to request for expression of interest for development of new generation assets.
• Counseled a municipal waste hauler (ARB Waste) on permitting, compliance, recycling, and location/siting matters related to its Puerto Rico operations, expansion plans, and potential sale.
• Counseled a government entity on superfund liability and compliance matters involving two former municipal landfill sites listed by the US EPA in the National Priorities List (former Juncos Landfill; former Vega Baja Landfill). Negotiated between potentially responsible parties and the US EPA on liability apportionment, long-term operation and maintenance plans, reporting and overall compliance, landfill closure, community relations, and residential relocation issues.
• Worked with counsel and management for ExxonMobil in a $90 million administrative penalty enforcement case under the RCRA/LUST program, Puerto Rico’s largest such enforcement case, including remediation, removal, health and geological assessments, and UIC issues, before the state environmental enforcement agency, the US EPA, and federal court proceedings.
• Worked with counsel and management of a major US filter-membrane manufacturer (commercial, medical, and pharmaceutical filters), in a $75 million administrative penalty enforcement case for hazardous solid waste under federal statutes RCRA and CWA. Advised client on regulatory compliance matters under federal and local statutes, litigation strategy, community and grassroots outreach, and related communications involving high-profile case.
• Worked with private and public sector clients on compliance, permitting, reporting, remedial, and removal actions involving commercial/corporate transactions, regulatory enforcement, reporting, facilities response plans, spill prevention control and countermeasures, contamination incidents from underground storage tanks, underground injection control systems, bulk petroleum, and fuel storage facilities and pipelines; review and counseling on business standards (including FCPA matters); RCRA, CAA, CWA, CERCLA, SDWA enforcement and permitting/reporting compliance matters.
• Worked on asbestos, lead paint enforcement, compliance, and removal matters, regarding real estate and M&A transactions.