Bob Comer

Co-Head of Mining, United States
Norton Rose Fulbright US LLP

United States
T:+1 303 801 2728
United States
T:+1 303 801 2728
Bob Comer

Bob Comer



Robert D. Comer has a diverse legal and scientific background in the mining, oil, gas, energy and natural resource industries focused on achieving business solutions to regulatory, compliance, permitting, operating, transactional and sensitive resource challenges. Bob has held senior leadership positions with industry and the federal government and is well known for his ability to design and implement effective legal and practical solutions.

During his tenure with the US Department of the Interior, Bob served as Associate Solicitor (now the Deputy Solicitor position) in Washington, D.C., where he directed legal strategy nationwide on matters pertaining to mining, oil, gas, energy, renewables, land use and water. As Rocky Mountain Regional Solicitor, he led one of the most active energy and litigation portfolios in the Department. Bob also has served as General Counsel and Chief Administrative Officer for a dual-listed gold company and as Associate General Counsel for a Fortune 500 mining, mineral processing and specialty metals company, where he had legal responsibility at most operating units and more than 30 superfund/NRD properties.

Bob is a leading authority in natural resource permitting and compliance, has testified before the U.S. Congress on mining law issues, and has advanced numerous resource projects.  He has counseled industry and government executives on a wide array of sensitive resource issues involving the Equator Principles, energy transmission, public land access, rights of way, NEPA permitting, endangered species, water quality and rights, wetlands, mineral estate title and security, royalties, superfund, toxics, environmental and land use compliance, enforcement, and litigation. Bob also has led negotiations involving commercial and mineral transactions, mineral leasing and mining law claims, and has participated in mergers, acquisitions and due diligence.

Bob currently serves as a Trustee to the Rocky Mountain Mineral Law Foundation and to the American Exploration & Mining Association and on the Advisory Board of the Western Energy Alliance.  Bob's service has included:  President, American Exploration & Mining Association; Chair, Colorado Bar Association Section on Natural Resource and Energy Law; Advisory Board, University of Colorado Innovative Energy Initiative; Officer, Colorado Mining Association; Chair, American Bar Association, National Committees on Mining, Public Lands and Resources, and Water Quality and Wetlands; and Director, Manufacturer's Edge.

Bob has been honored to be the Natural Resource Practitioner in Residence, University of Denver School of Law; and a recipient of the EPA Environmental Achievement Award, the Yale University, School of Forestry Alumni Class Award, the American Exploration & Mining Association Lifetime Member Award, and the Denver Business Journal Who's Who in Energy Law recognition. Bob received his Bachelor of Arts cum laude and Juris Doctor from the University of Colorado, Boulder, and a Master of Forest Science from the Yale University School of Forestry and Environmental Studies.

Professional experience

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JD, University of Colorado School of Law, 1987
MFS, Natural Resource Management and Ecology, Yale University, 1980
BA, cum laude, Environmental Biology and Conservation, University of Colorado, 1978

  • Colorado State Bar
  • Lawdragon 500 Leading Environmental & Energy Lawyers, Lawdragon, Inc., 2021 
  • Legal 500 USA, Recommended Lawyer, Industry focus - Energy Regulatory: Oil and Gas, The Legal 500, 2018
  • Legal 500 USA, Recommended Lawyer, Industry focus - Energy Litigation: Oil and Gas, The Legal 500, 2016, 2018 – 2019, 2021
  • Legal 500 USA, Recommended Lawyer, Industry focus - Energy Regulation: Conventional Power, 2021
  • Who's Who in Energy - Denver, The Business Journals, 2016– 2019
  • Distinguished Service Award, Yale University, Class of 1980
  • Environmental Achievement Award, Thorne Ecological Institute, 1986
  • Environmental Achievement Award, EPA, 2000
  • Landman's Legal Handbook, 5th ed., RMMLF, Contributing Editor
  • American Law of Mining, 2nd ed., Chapters 30 and 36, RMMLF, Contributing Editor
  • "Interpreting the Unnecessary or Undue Degradation Standard of FLPMA," RMMLF Annual Institute, Co-author with L. Wenger, 2008
  • "NEPA, Climate Change and Cumulative Effects – The Tip of the Iceberg" CLE International NEPA Conference, Las Vegas, Nevada and other locations, 2007
  • "NEPA in the Courts – Are Federal Agencies Complying with NEPA?" CLE International NEPA Conference, Denver, Colorado, 2007
  • "Mining and Environmental Protection on the Public Lands: The Necessary Coexistence of Two National Priorities," ABA 14th Annual Meeting, San Diego, California, 2006
  • "Messages from the Courts – A 10 Year Perspective on the Endangered Species Act," CLE International Tenth Annual Conference on the Endangered Species Act, 2004
  • "Mining Law Update," RMMLF Annual Institute, 2004
  • "Cooperative Conservation: The Federalism Underpinnings to Public Involvement in the Management of Public Lands," U. Colo. L. Rev. 75(4): 1133 – 1157, The Byron White Symposium on Constitutional Conflicts on Public Lands, 2004
  • "Agency Action Withheld – The Longstanding APA §706(1) Jurisdictional Rule after SUWA v. Norton," ABA 12th Annual Meeting, San Antonio, Texas, 2004
  • Chair, Colorado Mining Association Annual Meeting, 2015
  • CLE Co-Chair, Advanced Topics in Oil and Gas Law, CBA, 2015
  • CLE Co-Chair, Oil and Gas Nuts and Bolts, with Advanced Topics, CBA, 2014
  • Speaker, "Mission Creep: Emerging Scientific Issues in the Administration of the U.S. Endangered Species Act," Colorado Bar Association, Natural Resources and Energy Law Section, Monthly CLE Luncheon, 2014
  • Panel Leader, "Large Left Lateral Leaps for Environmental Professionals - Good Science, Federal Permitting and Good Governance - Wherefore Art Thou?," NWMA Annual Meeting, 2013
  • CLE Co-chair and speaker, Environmental Regulation of Energy Development, 2012
  • Panel Leader, "Environmental and Resource Policy Initiatives Affecting the Mining Industry under the Obama Administration," NWMA Annual Meeting, 2011
  • Speaker, "Energy Demand, Hydraulic Fracturing and Risk Management," AHC Annual Sustainability Workshop, 2011 
  • Colorado Bar Association, Natural Resources and Energy Law Section, Chair, 2014-2015 and Vice-Chair, 2013 2014
  • American Exploration & Mining Association, President (2018) and Board of Trustees, 2013 ​present
  • Western Energy Alliance, Board of Advisors, 2013 ​present
  • American Bar Association, Former Chair, Mining, Public Lands and Resources, and Water Quality and Wetlands Committees; Former Vice-Chair, Endangered Species and Annual Program Committees
  • Colorado Mining Association, Former Director and Officer
  • University of Colorado, Energy Innovation Initiative, Advisory Board, 2011 ​present
  • Colorado Association of Manufacturing and Technology, Board of Directors, 2012 ​present
  • American Bar Association, Editorial Board, Natural Resources and Environment Journal, 1991 ​2001
  • University of Colorado, Law Review, 1985 ​1987