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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 private equity firms 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 litigation and enforcement matters. Her areas of focus include onshore and offshore oil and gas regulation; solid and hazardous waste; oil and gas waste; 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 and Utica fields. She also counsels corporations on compliance with the Sarbanes-Oxley Act, 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.

Representative Matters

Oil and Gas Transactions
Advised oil and gas companies and private equity investors on the allocation of environmental liabilities in connection with the acquisition and divestiture of oil and gas properties in the Bakken, Barnett, Eagle Ford, Haynesville, Marcellus, Pearsall, and Utica Shales and the Uinta Basin.

Represented 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.

Represented 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.

Represented 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.

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

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, New Jersey, Oklahoma, Pennsylvania, 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 client 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).

Publications and Speeches

“Review of Case Laws Provides Insight into Jurisdiction of Federal Agencies,” Offshore Magazine, November 2015.

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 USA: America's Leading Lawyers for Business, Texas: Environment, 2006-2012
Legalease, The Legal 500 United States, Environment: Litigation, 2014; Energy: Transactions, 2015
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
Woodward/White, Inc., Best Lawyers, Environmental Law, 2009-2016