C. Boyden Gray

C. Boyden Gray


  • A.B. magna cum laude from Harvard and J.D. with high honors from the University of North Carolina at Chapel Hill. [1]


C. Boyden Gray (Clayland Boyden Gray) is an attorney and lobbyist and founding partner at the lobbying firm Boyden Gray & Associates in Washington, DC. He has been a lobbyist for a variety of corporations, including Exelon, First Energy Corporation, Amgen, Geneva Steel, Genzyme, New England Electric System, the Swiss Bankers Association, and Tiger Management. [1][2]

Gray is the grandson of Bowman Gray, a president of R.J. Reynolds Tobacco Company, and son of Gordon Gray who served as Secretary of the Army for President Truman and national security adviser to President Eisenhower. Gray has been described as a multimillionaire who has had numerous investments in oil partnerships according to disclosure forms from his days of service in government. [2]

According to his profile at Boyden Gray & Associates, Gray worked in the White House for twelve years, first as counsel to the Vice President during the Reagan administration and then as White House Counsel to President George H.W. Bush where he was “instrumental in the enactment of the Clean Air Act Amendments of 1990 and the Energy Policy Act of 1992, as well as the development of a cap-and-trade system for acid rain emissions.” [1]

While working on Clean Air Act revisions in the Bush administration, Gray touted the goal of a “free market” strategy – “the emphasis will be on market incentives to achieve results, getting away from command and control so there is more flexibility, more efficiency” in meeting clean air goals. [2][3]

C. Boyen Gray was chair of the Environmental Resources Trust (ERT), created in 1997 by the Environmental Defense Fund (EDF). A June, 1999 report by the NonProfit Accountability Project (PDF) detailed Boyden’s role at ERT, and critically examines both ERT and the EDF‘s role in climate change policy. The report comments that “It is disconcerting that Gray chairs ERT while simultaneously chairing Citizen’s for a Sound Economy (CSE), an anti-environmental think tank.” [2]

Gray founded the 501(c)(3) nonprofit Committee for Justice with political strategist Ed Rogers in 2002. The group describes itself as “the nation’s leading conservative voice on judicial appointments and the threat of judicial activism.” It initially served to pressure the Senate into approving President George W. Bush’s federal judicial appointments. [54], [53]

Koch Connection & Citizens for a Sound Economy

In 1993, C. Boyden Gray became the Chairman of Citizens for a Sound Economy (CSE), a group created by Richard Fink and founded in part by David H. KochCSE received $7.9 million between 1986 and 1993 from the Kochs. [5], [6]

At the time, CSE led a public relations campaign against the Clinton administration’s 1993 energy tax proposal. The Nation reported: “While the Koch Foundations could not legally lobby against the tax, CSE rallied public opposition, especially in Oklahoma, where then-Senator David Boren agreed to help kill the tax.” [7]

In 1995, the Kochs hired Gray to write federal legislation titled the Comprehensive Regulatory Reform Act of 1995 after the Environmental Protection Agency (EPA) had filed a lawsuit against the Kochs over oil spills at Koch-owned refineries. [4]

In 1999, Boyden Gray prepared a CSE-funded amicus brief key to a decision by a U.S. Court of Appeals in Washington that suspended air quality regulations issued by the Clinton-Gore administration in July 1997. CSE said it helped fund Gray’s brief. [4]

Stance on Climate Change

At the 1992 Earth Summit in Rio, Gray wrote that he believed more research was needed before action should be taken on climate change:

“[I]t may be that vigorous scientific research into global warming will soon demonstrate the need to act more drastically on greenhouse gases, but this has not happened yet … the immediate need is not climate change.” [2]

Key Quotes

October, 2014

“If policymakers are serious about cutting carbon emissions, they should give up heavy-handed mandates and empty promises in favor of policies that promote competition in the energy sector. Alternative fuels like natural gas have already reduced carbon emissions in electricity generation and could do the same in transportation. […]

Consider also nuclear power, which is much less carbon-intensive than coal and fossil fuels.” [8]

Key Actions

January 25, 2021

C. Boyden Gray published an article at the Wall Street Journal arguing that California and the Biden administration’s initiative to roll out state electric car quotas violated federal law. [55]

“To promote efficiency, federal law broadly forbids state regulations ‘related to fuel economy standards,” Gray wrote.  “Courts have held that this law forbids electric-car quotas and similarly meddlesome command-and-control policies that seek to dictate how car makers should meet federal performance standards. The Golden State argues that a special exception made for California regulations in the Clean Air Act should also be read into the federal fuel-economy law. But that law’s text says no. It forbids fuel-economy regulation by any state—no exceptions.” [55]

February 2016

C. Boyden Gray defended ExxonMobil in the media after the publication of documents showing that Exxon knew about climate change in the early 1980s while promoting climate denial for the next 27 years.  [9]

“The decision to single out Exxon is especially ill conceived, because when it comes to actual proposals for real legislative action on climate change, Exxon’s advocacy has been indistinguishable from some of the leading environmental organizations,” C. Boyden Gray writes in Forbes magazine.[10]

June 2006

C. Boyden Gray was part of the lobbying effort against REACH (Registration, Evaluation, and Authorization of Chemicals), a bill put before the European Union which would equire “manufacturers to test industrial chemicals used in the manufacturing process to gather health and safety data,” reported the Wall Street Journal. [11] 


Boyden Gray prepared a CSE-funded amicus brief key to a decision by a U.S. Court of Appeals in Washington that suspended air quality regulations issued by the Clinton-Gore administration in July 1997. CSE said it helped fund Gray’s brief. [4]


Writing at The New RepublicHanna Rosin reported that Gray was a “natural leader” for a new group titled the Air Quality Standards Coalition (AQSC). The group, formed in 1996, came to represent more than 500 members including Texaco, Teneco, Philip Morris, Chevron, and Monsanto. In 1997, AQSC spent $100 million in attempts to combat rules that the EPA estimated would save 15,000 lives a year. [51], [52]

Rosin also noted a relationship between the AQSC and Citizens for Sound Economy (CSE), anther of Gray’s groups, which it used “to carry out the ‘grass-roots’ campaign.” However, the CSE kept a “virtuous distance from AQSC: “We are not a part of the coalition; we do not receive funding from them, and we do not work together,” said Brent Bahler, a CSE spokesman.  [51]

Rosin reported that, despite this, “CSE footprints show up all over the coalition agenda.” For example, she notes that “CSE officials met with coalition members last April to brief them on their $5 million educational campaign on the EPA rules. They got the American Petroleum Institute to agree to match all donations up to $600,000. Keeping up the appearance of a grass-roots effort by employing CSE is in fact crucial to the coalition. ‘NAM has recognized that re environmental issues, while the war will be won or lost in Washington, the battles will take place out there,’ says one member, according to the notes.”  [51]


The Kochs hired Gray to write federal legislation titled the Comprehensive Regulatory Reform Act of 1995. [4]


At the 1992 Earth Summit in Rio, Gray wrote that he believed more research was needed before action should be taken on climate change:

“[I]t may be that vigorous scientific research into global warming will soon demonstrate the need to act more drastically on greenhouse gases, but this has not happened yet … the immediate need is not climate change.”[2]


As a Counsel to President Bush, Gray lobbied against the U.S. support for binding targets in the global warming treaty at the 1992 Earth Summit in Rio. Gray also opposed the President’s attendance at the event.  [2], [12]

During the Earth Summit at Rio, Gray opposed the views of many environmentalists and scientists when he said that “it may be that vigorous scientific research into global warming will soon demonstrate the need to act more drastically on greenhouse gases, but this has not happened yet … the immediate need is not climate change.” [13]


Gray denounced CAFE (Corporate Average Fuel Economy) standards that would improve the overall efficiency of vehicles on the road: “automobile companies cannot produce the kinds of cars that a portion of the public wants – big station wagons, for instance,” he said. He blamed U.S. job losses to the shift of production of large cars abroad, which allowed manufacturers to bypass CAFE standards. [2][14]

Gray was a member of Reagan’s Presidential Task Force on Regulatory  Relief, which made repealing CAFE standards one of its priorities. Citizens for a Sound Economy was also in opposition to CAFE standards. [2][15]


Lobbying History

Both OpenSecrets.org and the U.S. Senate Lobbying Disclosure Acts Database have records of Boyden C. Gray’s lobbying history. [48], [50]

View the attached spreadsheet for additional details on C. Boyden Gray’s lobbying by year and lobbying firm (.xlsx).

Client20122011201020062005200420032002200120001999Grand Total
AMGEN INC    $0$60,000$120,000$140,000$40,000$140,000$20,000$520,000
CITIBANK       $0 $20,000$80,000$100,000
Constellation Energy  $45,000        $45,000
DEUTSCHE TELEKOM AG        $560,000$840,000 $1,400,000
Exelon$0$5,000         $5,000
First Energy Corporation$30,000$60,000         $90,000
FiTeq, Inc.           $0
GENZYME CORP       $0$0$20,000$20,000$40,000
LYONDELL CHEMICAL CO   $20,000$20,000      $40,000
NETWORK SOLUTIONS         $20,000 $20,000
SWISS BANKERS ASSN         $20,000$20,000$40,000
TIGER MANAGEMENT CORP          $30,000$30,000
WYETH      $140,000$160,000   $300,000
Grand Total$30,000$65,000$45,000$20,000$20,000$60,000$260,000$300,000$600,000$1,060,000$170,000$2,630,000

Social Media

@BoydenGrayAssoc on Twitter.


Below are some sample publications and speeches from Boyden Gray’s profile at the Federalist Society. [49]


25 Years of Justice Clarence Thomas – Podcast 

28-Jun-16Practice Groups Podcast 

Governmental Power versus Free Speech? – Podcast 

16-May-16Practice Groups Podcast 

Deference Meets Delegation: Which is the Most Dangerous Branch? – Event Audio/Video 

18-Nov-152015 National Lawyers Convention 

EPA’s Use of Co-Benefits 

24-Sep-15Engage Volume 16, Issue 2 

International Trade: New Initiatives 

11-Sep-15Engage Volume 16, Issue 2 

Costs and Benefits vs. Smoke and Mirrors – Audio/Video 

24-Jun-15Third Annual Executive Branch Review Conference 

Separation of Powers – Event Audio/Video 

19-Nov-122012 National Lawyers Convention 


21-Jun-12Dodd-Frank Challenged in Court 

Power and Constraint: The Accountable Presidency After 9/11 – Event Video 

21-Mar-12Faculty Division and the American Enterprise Institute 

Congress vs. Agencies: Balancing Checks and Efficiency: Gridlock, Organized Interests, and Regulatory Capture – Event Audio/Video 

03-Mar-122012 Annual Student Symposium 

The Regulatory Accountability Act – Podcast 

17-Feb-12Administrative Law & Regulation Practice Group Podcast 

Discussion on the Legal and Constitutional Issues Concerning the Dodd-Frank Act – Event Audio 

06-Oct-11The Piedmont Triad Lawyers Chapter 

The Dodd-Frank Wall Street Reform & Consumer Protection Act of 2010: Is It Constitutional? 

23-Dec-10Engage Volume 11, Issue 3, December 2010 

Equality, Liberty, and Risk – Event Audio/Video 

20-Nov-102010 National Lawyers Convention 

The Constitutionality of the Dodd-Frank Financial Services Reform Act – Event Audio/Video 

19-Nov-102010 National Lawyers Convention 

The Dodd-Frank Wall Street Reform & Consumer Protection Act of 2010: Is It Constitutional? 

16-Nov-10Engage Volume 11, Issue 3 

Showcase Panel II: Bailouts and the Government as Insurer of Last Resort – Event Audio/Video 

13-Nov-092009 National Lawyers Convention 

C. Boyden Gray Address at the 2007 National Lawyers Convention – Event Audio/Video 

15-Nov-072007 National Lawyers Convention 

Clarence Thomas Address at the 2007 National Lawyers Convention – Event Audio/Video 

15-Nov-072007 National Lawyers Convention 

Judicial Confirmations Debate Transcript 


Agency Discretion and Restoring the Reign of Reason to the NSR Program 


Breaking the Compact: Separation of Powers, Deference and Fair Notice in New Source Review 


Controlling the “Fourth Branch”: The Fight Against Agency Capture May be a Losing Battle 


Andrew Card Address Before The Federalist Society at the 2003 National Lawyers Convention 


C. Boyden Gray Reviews “Judge Dave and the Rainbow People” – by Judge David Sentelle 


What Next for Negotiated Rulemaking? – Transcript 


Colloquium: The Future of Environmental Reform 

01-Dec-96Environmental Law & Property Rights Practice Group Newsletter – Volume 1, Issue 1, Fall 1996 


  1. C. Boyden Gray,” Boyden Gray & Associates. Archived February 18, 2016. Archive.is URL: https://archive.is/WJQBk
  2. “CRONY ENVIRONMENTALISM” (PDF), NonProfit Accountability Project, June, 1999.
  3. Marie Cocco. “A Free-Market Wrinkle Added By President,” Newsday , 4. 3-13-1989.
  4. Koch’s low profile belies political power,” The Center for Public Integrity, July 15, 2004. Archived August 17, 2016. Archive.is URL: https://archive.is/fEqMc
  5. Jane Mayer. “Covert Operations,” The New Yorker, August 30, 2010. Archived .pdf on file at DeSmogBlog.
  6. “Koch brothers now at heart of GOP power,” Los Angeles Times, February 6, 2011. Archive.is URL: https://archive.is/VZUEZ
  7. Sidebar: Petrodollar Scholars,” The Nation, 1997. Archived January 17, 1997. Archived .pdf on file at DeSmogBlog. Archive.is URL: https://archive.is/35e7G
  8. C. Boyden Gray. “Obama’s empty promises, go-it-alone policies won’t fight climate change,” The Washington Times, October 28, 2014. Archived February 23, 2016. Archive.is URL: https://archive.is/xxI3X
  9. Suzanne Goldenberg. “Exxon knew of climate change in 1981, email says – but it funded deniers for 27 more years,” The Guardian, July 8, 2015. Archived February 23, 2016.  Archive.is URL:  https://archive.is/rb6T1
  10. C. Boyden Gray. “The Misguided ExxonMobil Climate Change Inquisition,” Forbes, February 11, 2016. Archived .pdf on file at Desmog. Archive.is URL: https://archive.is/fWXFN
  11. Mary Jacoby. “EU Chemicals Proposal Prompts Global Mobilization Led by U.S.” The Wall Street Journal, June 27, 2006. Archived .pdf on file at Desmog. Archive.is URL: https://archive.is/F1uW8
  12. Michael Weisskopf. “Bush to Attend Rio ‘Earth Summit’ in June; Decision Follows U.S.-Won Concessions in Draft Language on Limiting Pollution,” The Washington Post , A3. 5-13-1992.
  13. C.Boyden Gray. “Put the Forests First,” The Washington Post, A19. 6-2-1992.
  14. Associated Press. “Bush panel urges end to ’70s fuel standards,” The New York Times, B5. 12-23-1986.
  15. Joel Bucher. “Smaller, more fuel efficient but deadlier cars,” The Washington Times, A17. 2-13-1996.
  16. National Council,” American Enterprise Institute. Archived June 1, 2016. Archived .pdf on file at DeSmogBlog. Archive.is URL: https://archive.is/y94Kg
  17. “Risk and Reward: U.S.-EU Regulatory Cooperation on Food Safety and the Environment” (PDF), Atlantic Council of the United States, November, 2002. Archived .pdf on file at Desmog.
  18. “What is the Environmental Resources Trust (ERT)?” Environmental Resources Trust. Archived March 8, 2000. Archive. is URL: https://archive.is/BZ5hl
  19. “FreedomWorks Foundation Inc,” (PDF) 2013 form 990, Conservative Transparency. Archived .pdf on file at DeSmogBlog.
  20. Board of Trustees,” Friends of Choice in Urban Schools. Archived February 21, 2005. Archive.is URL: https://archive.is/HEfEW
  21. “Citizens for a Sound Economy Educational Foundation” (PDF), Greenpeace research documents. Archived .pdf on file at DeSmogBlog.
  22. Board of Trustees,” Marshall Foundation. Archived April 1, 2004. Archive.is URL: https://archive.is/sZsy2
  23. Leadership,” The Campaign Finance Institute. Archived August 4, 2005. Archive.is URL: https://archive.is/fM7qz
  24. Frequently Asked Questions,” Reason Foundation. Archived August 16, 2016. Archive.is URL: https://archive.is/EBdui
  25. Board of Trustees,” Center for the Study of the Presidency. Archived February 8, 2006. Archive.is URL: https://archive.is/egVGc
  26. Board of Directors,” Center for Global Development. Archived November 18, 2010. Archive.is URL: https://archive.is/D2JTb
  27. Partners Council,” Center for Global Development. Archived August 17, 2016. Archive.is URL: https://archive.is/kFnxZ
  28. Board of Directors,” Resources for the Future. Archived August 17, 2016. Archive.is URL: https://archive.is/0Gy35
  29. Board and Advisory Council,” Get America Working. Archived August 17, 2016. Archive.is URL: https://archive.is/KrbKY
  30. “2004 Was An Outstanding Year For Financial Performance and Journalistic Excellence” (PDF), Media General. Archived .pdf on file at Desmog.
  31. (Press Release). “Media General Announces Nomination of Rodney A. Smolla to Board of Directors and Resignation of C. Boyden Gray, New Ambassador to the European Union,” Media General, February 21, 2006. Archived August 17, 2006. Archive.is URL:https://archive.is/aOr6F#selection-127.0-127.148
  32. Kim Sunderland. “Advisory Group Named to Design FCC Reform Plan,” Channel Partners, December 1, 2000. Archived August 17, 2016. Archive.is URL: https://archive.is/bZAUZ
  33. C. Boyden Gray,” SourceWatch profile.
  34. “Overview: AMERICAN COUNCIL FOR RENEWABLE ENERGY Joint Session in Austin, Texas of the Texas Renewable Energy Industries Association with Solar Electric Power Association” (PDF), American Council for Renewable Energy, November 14, 2002. Archived .pdf on file at Desmog.
  35. Officers and Directors,” National Conservative Campaign Fund. Archived October 11, 2004. Archive.is URL: https://archive.is/tRjUp
  36. Board Of Directors National Legal Center,” National Legal Center for the Public Interest. Accessed August 17, 2016. Archive.is URL: https://archive.is/oy3Zv
  37. Board of Directors,” New Uses Council. Archived June 13, 2007 with Archive.is.
  38. About the Program,” Mercatus Center. Archived February 10, 2005. Archive.is URL: https://archive.is/d29th
  39. Organisation,” worldAgriculturalforum. Archived August 17, 2016. Archive.is URL: https://archive.is/BJDES
  40. Dan Morgan. “A Debate Over U.S. ‘Empire’ Builds in Unexpected Circles,” The Washington Post, August 10, 2003. Archive.is URL: https://archive.is/7kc32
  41. The Board,” DataPharm Foundation. Archived April 3, 2004. Archive.is URL: https://archive.is/MiJzr
  42. Steering Committee,” Energy Future Coalition. Archived August 17, 2016. Archive.is URL: https://archive.is/qxj8v
  43. Enterprise for the Environment,” Center for Strategic and International Studies. Archived February 8, 2005. Archive.is URL: https://archive.is/ZfSzK
  44. (Press Release). “CSIS Establishes U.S. Nuclear Energy Project (USNEP) and Forms New Commission on Nuclear Energy Policy in the United States,” CSIS, October 14, 2011. Archived August 17, 2016. Archive.is URL: https://archive.is/4tbDd
  45. Special Report: Reform of Risk Regulation: Achieving More Protection at Less Cost,” Human and Ecological Risk Assessment Vol. 1., No. 3, pp. 183-206, 1995. Retrieved from Truth Tobacco Industry Documents, Bates Number : 800160769-800160793. Archived.pdf on file at Desmog.
  46. Tobacco, Tea Party, and Dirty Energy: Lobbyist C. Boyden Gray,” Checks and Balances Project, March 25, 2013. Archived February 18, 2016. Archive.is URL: https://archive.is/7SDbv
  47. C. Boyden Gray,” George Mason University. Archived June 1, 2016. Archived .pdf on file at DeSmogBlog. Archive.is URL: https://archive.is/9Fd8x
  48. Cray, C. Boyden: Lobbyist Profile,” OpenSecrets.org. Accessed August, 2016. 
  49. Hon. C. Boyden Gray: Founding Partner, Boyden Gray & Associates,” The Federalist Society. Archived August 17, 2016. Archive.is URL: https://archive.is/DgGVT
  50. Search Results, U.S. Senate Lobbying Disclosure Acts Database. Accessed August 29, 2016.
  51. SHADES OF GRAY,” The New Republic, April 14, 1997. Retrieved from MediaTransparency.org. Archived March 18, 2005. Archive.is URL: https://archive.is/Zjj70
  52. EPA Clashes with Industry,” The Detroit News, February 7, 1999. Retrieved from Greenpeace Investigations.
  53. A Moving Force In Fight for Bush’s Judicial Nominees,” The Washington Post, May 24, 2005. Archived September 20, 2018. Archive.is URL: https://archive.fo/sx21O
  54. About the Committee for Justice,” Committee for Justice. Accessed September 20, 2018.
  55. C. Boyden Gray. “Electric Car Quotas Have a High Cost,” Wall Street Journal, January 25, 2021.  Archive URL: https://archive.ph/l3K28

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