Regulatory Advocacy

Theresa Pugh has been working for industry in regulatory advocacy since joining National Association of Manufacturers (NAM) in 1983. She has worked for a variety of trade associations including NAM, American Petroleum Institute (API), American Forest & Paper Association (AF&PA) and, with the American Public Power Association (APPA) from 2001-2015. While at APPA she was concerned with how the power sector would adjust mostly from coal to generation largely with natural gas and renewables to comply with increased EPA regulations and market forces. In that capacity she managed a research project on natural gas conversion pointing to the many complexities for the power sector’s new Clean Power Plan (a comprehensive CO2 regulatory program that will dramatically alter the electricity sector). In addition to managing the extensive comments she worked on materials for the industry’s rating agencies and state regulatory agencies to understand the dramatic changes that stretch far beyond environmental policy.

She served as Vice President of Interstate Natural Gas Association of America (INGAA) (2015-March 2016) where she managed the methane question pertaining to the proposed methane NSPS for the pipeline industry.

Consulting Work

In her new consulting capacity, she is representing the oil and gas industry on water issues. She has a unique understanding of the upstream, midstream, downstream energy sectors, the electricity sector, and how the two interrelate.

Theresa’s 2016-2017 consulting work includes representing U.S. product manufacturers to be regulated by the new TSCA law and regulations.

Her policy background offers insights into the need to ensure just and reasonable rates for electricity customers while understanding the new generation regulatory issues which can affect system reliability and impact both industrial and residential customers.

She has a BA from Trinity University in San Antonio, Texas and attended the London School of Economics (non-degree program). She lives in Alexandria, VA. She worked for the Texas Legislature and U. S. Senator John Tower (R-Deceased).

Overview of Clients / Areas of Experience

  • Electric generation
  • Refining
  • Pulp and paper
  • General manufacturing
  • Natural gas & oil producers in Marcellus/Utica regarding power plant customers
  • Private Equity (confidential)  consulting regarding natural gas for electric power, pipeline safety regulations, & shale markets
  • Industrial uses of natural gas as fuel or for processing commodity products
  • Impacts of electricity pricing for manufacturing plants
  • Natural gas pipelines (permitting, environmental regulations, and need for power generation fuel switching)
  • Manufacturing power island or power plant biomass as fuel issues before U.S. EPA
  • Public policy issues to encourage use of Liquified Natural Gas (LNG) for domestic supply and infrastructure readiness
  • Regulatory reform analysis and advocacy before U.S. EPA, Department of Energy, FERC (technical conferences), Department of Commerce & U. S. EPA
  • Subcontracting service for >200 electric utilities (public power and investor utility owned) across 18 states in three diverse geographic regions
  • Liquified Natural Gas (LNG) client, research


Specializing in Federal regulations that affect small business

Since the early 1990s Theresa has participated in nine U. S. Small Business Administration (SBA) Small Entity Representative panels reviewing proposed regulations ranging from carbon dioxide regulations on power sector, fish protection/water intake regulations to industrial boiler/power plant regulations to control mercury to regulations. Participation in these panels means reviewing the proposed rules with knowledge of Regulatory Flexibility Act (RFA) and Executive Order 13272. These extra steps “require federal agencies to determine the impact of their rules on small entities, consider alternatives that minimize small entity impacts, and make their analyses available for public comment”. Theresa works with the U. S. SBA’s Office of Advocacy giving small firm owners (or their trade associations) a chance to make their voices heard about rules that affect their interests. Theresa’s experience makes certain that small businesses can properly use this process to their advantage.

Theresa’s background can assist small trade associations with busy staff to focus on these proposed regulations and advocate on their behalf. Theresa can take a leadership role or can simply monitor the issues for the trade association. Theresa can also assist with associations or companies seeking one on one meetings with key regulatory staff in EPA’s Research Triangle Park office or at EPA Headquarters.

“In the last seven years 3,900 rules were issued resulting in almost 76,000 pages of regulations in Federal Register. More than 200 of these final rules were from U.S. EPA.”

–Washington Examiner

Read the article


  • U. S. Chamber of Commerce Environmental Committee
  • Global Energy Institute
  • US Chamber Small Business Council



“I was impressed by [Theresa’s] comprehensive analysis…The response was really helpful and insightful for [name of company removed ] designing a long term research plan.”

CEO, client regarding his nation’s comprehensive energy decarbonization plan. Nation is in top ten gross domestic production (GDP) and member of OECD and G-20. Project was completed in one day for client.
April 2020

“Theresa always has a pulse on the aspects of rulemaking that may go unnoticed by the less experienced.  She brings a wealth of knowledge and energy to the table, providing significant depth and attention to detail that has served our clients well.  Her relationships with key players in the regulatory space give her insights into what utilities and others can expect going forward, and her institutional knowledge and keen eye for nuance make her reports that much more thorough.”

Elizabeth K. Whitney
Managing Principal Meguire Whitney
Washington, DC

Pugh (third from right) is member of U.S. Chamber of Commerce’s Small Business Council (SBC).

Following SBC meeting attendees visited The Washington Post news room and learned about the real time reader analysis. SBC offered an informative meeting to discuss policy/regulatory issues for small manufacturers and entrepreneurs.