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 focused on achieving business solutions to regulatory, compliance, permitting, operating and transactional challenges in the mining, oil, gas, energy and other natural resource industries.  Bob has held senior leadership positions with industry and the federal government and is well known for his ability to design and implement effective solutions to legal challenges impeding permitting, operations and corporate objectives.

During his tenure with the U.S. Department of the Interior, Robert served as Associate Solicitor 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, where 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-exchange 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 company operating facilities and more than 30 superfund/NRD properties. 

Bob is considered a leading authority in natural resource permitting and compliance and has led numerous projects. He has counseled industry and government executives on a wide array of issues involving 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 permit compliance, enforcement, and litigation. Bob also has led negotiations involving commercial and mineral transactions, oil, gas and other mineral leasing and mining law claims, and has participated in mergers, acquisitions and related due diligence efforts.

Bob currently serves as  Chair to the Colorado Bar Association Section on Natural Resources and Energy Law, a Board Member of the American Exploration and Mining Association (formerly Northwest Mining Association), on the Advisory Board of the Western Energy Alliance, on the Advisory Board of the University of Colorado Innovative Energy Initiative and on the Board of Directors for Manufacturer's Edge (formerly Colorado Association of Manufacturing and Technology). 

Robert was the Distinguished Natural Resource Practitioner in Residence at the University of Denver School of Law, a Trustee to the Rocky Mountain Mineral Law Foundation, a Director and Officer of the Colorado Mining Association and has Chaired the American Bar Association's National Committees on Mining, Public Lands and Resources and Water Quality and Wetlands.  He 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
  • 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
  • Who's Who in Energy - Denver, The Business Journals, 2016-2018
  • 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