Jump to Navigation
Heather Palmer
P: +1.713.221.1526
F: +1.800.404.3970

Kim Gray


Heather Corken Palmer offers clients in-depth environmental regulatory knowledge and experience in energy-related environmental issues. As a partner in the environmental strategies group, Heather helps energy, petrochemical and pipeline companies and clients in the power and utility sector that are seeking guidance on environmental compliance and the allocation of environmental liabilities in mergers and acquisitions.

She practices all aspects of environmental law, advising clients on regulatory requirements, assisting them in the evaluation and negotiation of corporate and real estate transactions and representing them in environmental enforcement matters. Her areas of focus include onshore and offshore oil and gas regulation; solid and hazardous waste; oil and gas waste; coal combustion residuals (coal ash); environmental remediation; water quality; water rights; wetlands; endangered species; Superfund litigation; and compliance with the National Environmental Policy Act. She plays a major role in advising clients on the environmental issues surrounding shale play development, hydraulic fracturing and the permitting, construction and operation of liquefied natural gas (LNG) import/export facilities in the U.S.

Heather has assisted clients in the allocation of environmental liabilities in connection with the acquisition and divestiture of oil and gas properties in all of North America's major shale plays, including the Bakken, Barnett, Eagle Ford, Haynesville, Marcellus, Pearsall, Utica and Woodford Shales and the Anadarko, Permian and Uinta Basins.  Her practice includes advising clients in the power and utility sector on environmental compliance and the allocation of environmental liabilities in acquisitions and divestitures of electric generating facilities and district energy assets.  She also counsels corporations on disclosure of environmental matters in public filings and meeting the requirements of the Bureau of Safety and Environmental Enforcement's Safety and Environmental Management Systems (SEMS) regulations.


Oil and Gas Transactions
Apache Corporation in the $1.4 billion sale of approximately 90,000 net acres in southern Louisiana and 115,000 net acres in the Anadarko Basin.

Howard Midstream Energy Partners, LLC in its negotiation of a purchase and sale agreement to acquire northeast Pennsylvania gathering assets in Bradford and Lycoming counties from Southwestern Energy Company for $500 million.

Chevron Corporation in the sale to ONEOK Partners, LP. of the Mesquite Pipeline and its 80% interest in the West Texas LPG Pipeline Limited Partnership for approximately $800 million.

Chevron Pipe Line Company and Chevron Midstream Pipelines LLC in the sale of Gulf Coast natural gas pipeline assets to EnLink Midstream Partners, LP and EnLink Midstream, LLC for $235 million.

Chevron Pipe Line Company in the sale of Chevron Petrochemical Pipeline LLC, which owns the Evangeline ethylene pipeline system for $295 million, to Boardwalk Pipeline Partners, LP.

Chevron in the sale of its Ferndale, Washington butane/propane storage and distribution facility for $242 million to Petrogas Energy Corp.

Pioneer Natural Resources Company in the sale of all of its assets in the Hugoton field for $340 million.

Pioneer Natural Resources Company in the sale of Permian Basin assets to Three Rivers for $58 million.

Noble Petro Inc. in the sale of six of its storage and distribution terminals to U.S. Oil.

Phillips 66 in the sale of Phillips Specialty Products Inc., a flow improver business, to Berkshire Hathaway Inc. in exchange for shares of Phillips 66 common stock held by Berkshire Hathaway valued at $1.4 billion.

A privately held independent oil and gas company in the $1.45 billion sale of oil and gas properties in the Bakken shale in North Dakota.

A New York Stock Exchange-listed oil and gas exploration and production company in multiple acquisitions of oil and gas properties in the major shale plays in the U.S., totaling more than $400 million.

An independent petroleum and natural gas exploration and production company in the sale of 35% of their interest in oil and gas leases located in the Pearsall Shale in Texas to Japan's second largest gas company.

A Fortune 500 company in its $2.16 billion acquisition of a major manufacturer of chemicals used in operating oil and gas wells.

Power Transactions
Great Plains Energy Incorporated in its pending acquisition of Westar Energy, Inc. in a combined cash and stock transaction valued at approximately $12.2 billion.

Talen Energy Corporation in the $1.175 billion acquisition of MACH Gen, LLC, the holding company of three natural gas-fired power plants located in New York, Massachusetts and Arizona with a total capacity of over 2,500 MW.

Rockland Capital, LLC in the acquisition of 100% of the interests in Michigan Power LP, LLC, the owner of  a 125 MW natural gas-fired combined cycle cogeneration facility in Ludington, Michigan.

Integrys Energy Group, Inc. in the sale of a portfolio of over 50 distributed solar projects to TerraForm Power, LLC.

Optim Energy, LLC in the $126 million sale of its Twin Oaks power plant, a 305 MW coal-power facility located in Robertson County, Texas, to a unit of Blackstone as part of a Section 363 sale process.

La Caisse de dépôt et placement du Québec in its $593 million acquisition of minority equity interests in holding companies of Indianapolis Power & Light Company from The AES Corporation.

Environmental Counseling
Assisted a major energy company in a comprehensive review and update of its environmental, health and safety procedures.

Advised an international drilling company on compliance with environmental and safety requirements in the U.S. Gulf of Mexico and assisted in a comprehensive review and update of the company’s environmental policies and procedures.

Represented a New York Stock Exchange-listed energy company in connection with the construction, permitting and operation of LNG import/export facilities in Sabine Pass, Louisiana and Corpus Christi, Texas.

Advised a major independent oil and natural gas exploration and production company on compliance with BSEE's Safety and Environmental Management Systems (SEMS) regulations in the U.S. Gulf of Mexico and assisted in development of the company's SEMS program.

Provided counsel to international oil and gas, energy and manufacturing companies on the disclosure of the financial impacts of environmental compliance and loss contingencies, including the potential impact of climate change, greenhouse gas emissions, and hydraulic fracturing on business operations and financial performance, in their 10-Ks, 10-Qs and other public filings.

Assisted in obtaining Section 404/Section 10 permits from the U.S. Army Corps of Engineers (USACE), preparing permittee-responsible mitigation plans, and negotiating contracts for compensatory wetlands mitigation in connection with the construction of major energy projects and chemical facilities in Texas and Louisiana.

Environmental Enforcement
Provided counsel to clients named as potentially responsible parties under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) at state and federal Superfund sites in Alabama, Arkansas, Arizona, California, Georgia, Illinois, New Jersey, Oklahoma, Pennsylvania, South Carolina, Tennessee, and Texas, including serving as common counsel in connection with the Many Diversified Interests Superfund Site in Houston, Texas.

Negotiated with the United States Environmental Protection Agency (EPA), the United States Department of Justice (DOJ) and other federal and state regulatory agencies to reduce settlement amounts on behalf of clients.

Defended a hazardous waste treatment, storage and disposal company in a multimillion dollar enforcement action brought by the EPA and the DOJ under the Resource Conservation and Recovery Act (RCRA) and corresponding state law.

Negotiated reduced settlement amounts for clients in enforcement actions brought by the EPA and states under RCRA, the Emergency Planning and Community Right-to-Know Act (EPCRA), the Clean Water Act (CWA), and the Clean Air Act (CAA).


Co-author, “Watch Your Wallet-Federal Penalties Are Going Up,” InsideCounsel, July 15, 2016.

Co-author, “Wyoming Federal Judge Sides with States Industry, Strikes Down BLM Hydraulic Fracturing Rule,” Oil & Gas Financial Journal, July 15, 2016. 

Co-author, “Another Win for Statewide Regulation of Hydraulic Fracturing,” Oil & Gas Financial Journal, May 2016. 

Presenter, “Addressing Environmental Issues in Energy Transactions,” Association of Corporate Counsel South/Central Texas Chapter's Oil & Gas Law Lunch and Learn, San Antonio, April 28, 2016.

“Regulatory Perspectives: Safety Jurisdiction on the Outer Continental Shelf,” Offshore Magazine, November 2015.

Co-author, “California Hydraulic Fracturing Update,” Oil & Gas Financial Journal, August 12, 2015.

“Local Regulation of Oil and Gas:  The Battle Continues,” Modern Shale Gas & Oil Production Forum, The Aspen Institute, June 2015.

“Regulatory and Infrastructure Challenges,” Ground Water Protection Council Annual Forum, October 2014.

“OCS Regulatory Update,” Offshore Safety Conference USA 2014, September 2014.

Co-author, “EPA Considering Major Changes to Risk Management Program,” The National Law Review, August 11, 2014.

Co-author, “Battles Continue over Local Bans on Hydraulic Fracturing,” Oil & Gas Financial Journal, August 7, 2014.

“Regulatory and Infrastructure Challenges,” Modern Shale Gas & Oil Production Forum, The Aspen Institute, July 2014.

Co-author, “Secrets to the Boom Revealed,” Energy Executive Magazine, June 2014.

Co-author, “LNG Regulatory Prospects for 2014,” Oil & Gas Financial Journal, March 2014.

Moderator, “Updates on North American Projects in Development,” Platts 13th Annual LNG Conference, February 2014.

Panelist, “Offshore Safety,” Bracewell Environmental Forum, February 2014.

Panelist, “Project Opposition: The Expanding NGO Toolkit,” Bracewell Environmental Forum, February 2014.

Co-author, “LNG Exports Year in Review: Unfreezing Regulatory Approvals,” Oil & Gas Financial Journal, January 6, 2014.

Co-author, “California's Next Frontier: Development of the Monterey Shale,” Oil & Gas Financial Journal, December 2, 2013.

“Hydraulic Fracturing: The U.S. Experience,” Environmental Law and Regulation in Alberta Conference, November 2013.

“Environmental Challenges in the Marcellus Shale,” American Gas Association Sixth Annual Energy Market Regulation Conference, October 2013.

Author, "Environmental Implications of DOE's Approval of Fourth LNG Export Project," Oil and Gas Financial Journal, September, 30, 2013.

Co-author, "NY High Court to Hear Cases Determining Future of Hydraulic Fracturing," Oil and Gas Financial Journal, September, 12, 2013.

"Regulatory Challenges for Contractors in the Gulf of Mexico," Offshore Process Safety Conference, September 2013.

"Environmental Disclosures in SEC Filings," Texas Environmental Superconference, August 2013.

"Environmental Hurdles to LNG Export Approval," American Law Institute Webinar, June 2013.

"Environmental Considerations in Oil and Gas Leases," American Bar Association Webinar, June 2013.

"Offshore Environmental Issues: Things to Consider," PetroSkills, April 2013.

"The Path to Global Best Practices in Offshore Drilling," Texas Minority Counsel Program, October 2012.

"The New Texas Gold: Texas Regulation of Shale Gas in the Barnett, Haynesville and Eagle Ford Shales," West Virginia University College of Law Shale Gas Symposium, October 2011.

"Hot Topics in Document Production and Retention," Texas Environmental Superconference, August 2011.

"Navigating ‘Waters of the United States,’" Law360, May 4, 2011.

"Disclosure of Environmental Issues in SEC Filings," American Bar Association Conference on Environmental Issues in Region 6, June 2010.

Co-author, "BNSF A Year Later: Joint and Several Liability," Law 360, April 27, 2010.

"State and Federal Site Contamination Law," Texas Land Law Conference for Civil Engineers and Land Surveyors, March 2010.

"Ethical Considerations for the Wetlands Practitioner," Texas Wetlands Conference, February 2010.


J.D., Vanderbilt University, 1994
B.A., History and International Studies, cum laude, Rhodes College, 1991

Bar Admissions



Chambers & Partners, Chambers USA, Texas: Environment, 2006-2012, 2016
Legalease, The Legal 500 United States, Environment: Litigation, 2014; Energy: Transactional, 2015-2016
Woodward/White, Inc., Best Lawyers, Environmental Law, 2009-2017
Thomson Reuters, Texas Super Lawyers, 2010-2015
Thomson Reuters, Texas Super Lawyers Rising Stars, Environmental Law, 2006-2008
Lawdragon 3000 Leading Lawyers in the United States, 2010-2011
Lawdragon, 500 New Stars, New Worlds, 2006
H Texas, Houston's Top Lawyers, 2007