Kimberly Tuthill White

Senior Associate

Kimberly Tuthill White

Houston

P: +1.713.229.1166 F: +1.713.229.7966
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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

ESG

  • 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

Enforcement Defense

  • 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

Environmental Litigation

  • 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

Environmental Transactions

  • 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