David McCullough

Practice Areas

David is a recognized expert in the production, trade, shipment and use of renewable fuels, renewable natural gas, low-carbon energy and products, environmental and carbon credits, petroleum products and other energy commodities.

He serves as legal counsel on cutting-edge energy matters, including the development, acquisition and sale of renewable natural gas (RNG) facilities, advanced recycling facilities, renewable diesel and sustainable aviation refineries, carbon capture projects, reforestation projects and other low-carbon investments. For the past 15 years, David has helped guide the energy industry on the implementation of the Renewable Fuel Standard (RFS) and state low-carbon fuel standards (LCFS). He has been involved in almost every significant development associated with those programs, including not only investments and acquisitions incentivized by the RFS and LCFS, but also regulatory matters related to the implementation of every RFS rulemaking to date and some of the largest enforcement proceedings brought to date. He has developed what have largely become industry standard terms for the trade of RNG, RINs and LCFS credits, having served as counsel on over 40 RNG offtake transactions. He counsels clients on the reduction of greenhouse gas emission and cap-and-trade programs, carbon emission allowance and carbon offset trading, having helped form numerous funds to buy and hold carbon allowances and LCFS credits.

David seeks to provide full-service representation on his clients’ energy needs, providing counsel on the Environmental Protection Agency’s (EPA) mobile source regulatory program, trade issues, the Jones Act, U.S. Customs entry requirements, import and export controls and regulations governing shipping.