Kim advises clients on federal and state environmental regulatory compliance and represents them in environmental enforcement, litigation, permitting and transactional matters. Kim's environmental practice focuses on compliance counseling and enforcement defense for upstream and midstream oil and gas companies under state and federal air, water and waste environmental, oil and gas and pipeline safety regulations.
Kim has a particular focus on Environmental, Social, Governance ("ESG") and sustainability reporting issues. Kim assists companies with developing, implementing and reporting on ESG initiatives to demonstrate environmental best practices and long-term environmental resiliency and value.
Kim provides pipeline safety compliance counseling for companies' interstate and intrastate pipelines and gathering lines, including with integrity management, control room management, design, construction and corrosion control regulations. Kim has handled both internal and agency-led compliance audits under federal Pipeline and Hazardous Materials Safety Administration ("PHMSA") requirements and corresponding state regulations.
Kim is an avid reader, but lately spends her time reading primarily children's books with her toddler. Kim also mentors law students interested in environmental and regulatory careers. She is active in the Palmer Memorial Episcopal Church children's program and the Linkwood Civic Club Deed Restrictions Committee.
Compliance Counseling - Environmental
- Oilfield services company – Assisted as national counsel on hydraulic fracturing regulatory and legislative issues at the state, federal and international levels, specifically chemical disclosure requirements and trade secret protection
- Exploration and production company – Provided counseling during an environmental compliance audit of several assets in the Eagle Ford Shale under the Texas Environmental Health and Safety Audit Privilege Act
- Oilfield services company – Representation in federal and state rulemaking proceedings concerning oil and gas operations
- Oilfield services company – Assisted with permitting of oilfield waste recycling and disposal operations throughout the U.S.
Compliance Counseling - Pipeline Safety
- Pipeline company – assisted with PHMSA risk analysis and integrated assessment audits
- Exploration and production companies – assisted with applications for PHMSA special permits and regulatory waivers for variances from design and construction requirements to account for emerging technology
- Exploration and production company – Assisted with compliance assessment under state and federal pipeline safety and integrity management requirements for upstream and midstream pipelines in the Bakken Shale
- Chemical company – Assisted with internal audits of control room management and PHMSA requirements for gathering lines
- Exploration and production company – Assisted with analysis of sustainability initiatives to utilize lower carbon technology to reduce emissions; broader assessment of Scope 1, 2, and 3 greenhouse gas emissions; preparation of sustainable development scenario analyses; preparation of materials for rating agencies, including MSCI, S&P 500, Vigo Eiris, and Sustainalytics; and preparation of reports under GRI, SASB, TCFD, and CDP procedures, among others
- Exploration and production company – Counseled on ESG reporting metrics including greenhouse gas and flaring emissions intensity, water consumption and reuse, and safety incident rates; Assisted with coordination of internal company ESG reporting mechanisms; Counseled on strategy for setting and disclosing ESG targets; and Assisted with analysis of environmental litigation risk presented by ESG reporting
- Natural gas producer – Assisted with analysis of peer group sustainability reports and trends analysis of the intersection between corporate governance and environmental sustainability reporting
- Upstream and midstream operator – Assisted with 2 degree climate scenario analysis and counseling on overall sustainability reporting recommendations and strategy
- Chemical company – Counseled on broader sustainability/ESG reporting opportunities, initiatives and strategy
- Oilfield services company – Counseled on sustainability issues associated with hydraulic fracturing fluids; Assisted with analysis of trends, including ESG metrics, integrated reporting, and incorporation of TCFD measures; Provided feedback for sustainability reporting metrics and data
- Pipeline company – defended contested PHMSA enforcement matters relating to alleged pipeline integrity, mapping and incident prevention issues
- Midstream company – defended federal Clean Air Act Risk Management Plan enforcement matters
- Midstream company – defended federal Clean Air Act Leak Detection and Repair enforcement matter
- Upstream companies – defended state air and waste enforcement matters involving production and service company operations
- Midstream company – represented appeals of Texas Commission on Environmental Quality compliance history classifications for various midstream assets
- Exploration and production company – Assisted with the defense of state law claims alleging damage from air emissions associated with exploration and production operations in the Eagle Ford Shale
- Oilfield services company – Assisted with the defense of Wyoming's hydraulic fracturing trade secret protection regulations before the state district court and the appeal (pending) before the Wyoming Supreme Court
- Investors in offshore oil and gas assets – Advised foreign investors regarding the environmental regulatory requirements applicable to and legal risks associated with U.S. offshore oil and gas operations in the Gulf of Mexico
Global Legal Chronicle
2020 Baker Botts Environmental, Safety, and Incident Response Seminar