Paul Tough

My practice entails a wide range of environmental, water and energy matters. I have represented operators, landowners, commercial entities, municipalities, and groups/associations from across the State in numerous hearings before the Railroad Commission of Texas, the Texas Commission on Environmental Quality, the General Land Office, and in Courts throughout Texas. Just some examples of the types of proceedings include oil and gas well permitting (spacing and density exceptions), field rules, disposal wells, flaring, mineral interest pooling act, water discharge permitting, air quality permitting, water rights, landfills, mining, enhanced oil recovery, environmental audits, and enforcement matters. Sometimes these matters end up in state and federal courts. We have experience in handling those matters too and others related to the environmental, water, and energy sector.


Before joining McElroy Sullivan, I spent two years as an attorney and clerk with the Texas Commission on Environmental Quality. My practice focused on water quality (discharge permitting) and water utilities. Principally that work involved advising the Executive Director on water quality permitting matters, responding to public comment and hearing requests, representing the Executive Director before the Commissioners and at the State Office of Administrative Hearings. I participated in multiple contested case hearings and worked with the attorney general on several appeals. My experience at TCEQ has helped my practice at MSMW. In addition my background in engineering has helped with handling technical cases. I have also served as the Chair, Vice-Chair, Treasurer, and Secretary of the Oil and Gas Section of the Austin Bar Association.



  • Austin Bar Association Oil and Gas Law Section
    • Chair 2015-2016
    • Vice-Chair 2014-2015
    • Treasurer 2013-2014
    • Secretary 2012-2013
  • Austin Bar Association Environmental Law Section – Member
  • Austin Bar Association Administrative Law Section – Member



  • Author, Drilling Waste Disposal, Advanced Oil, Gas and Energy Resources Law.
  • Author, City of Dish: Potential New Air Requirements on Oil & Gas Production Sites, Advanced Oil, Gas and Energy Resources Law.


  • Energy
  • Environmental
  • Water
  • University of Texas at Austin, B.S. Chemical Engineering
  • University of Miami, J.D. cum laude
  • State Bar of Texas, 2005