Chief Administrative Officer and General Counsel, International Tower Hill Mines Ltd
Robert “Bob” Comer has served on the Manufacturer’s Edge Board since early 2012. He has extensive experience serving as general counsel in the public and private sectors, including to the US Department of the Interior, and multiple mining corporations. Comer possesses a wide breadth of specialization in environmental and land law, especially pertaining to natural resources, pollution, mining, and compliance.
Comer is a sought-after speaker on ecology, renewable energy, and the protection of private lands. He is also extensively published in the environmental law arena.
CAREER HISTORY
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- International Tower Hill Mines, Colorado, CAO, General Counsel & Secretary, January 2012 – Current
- Faegre Baker Daniels, Partner , 2010 – 2012
- University of Denver, Sturm School of Law, Distinguished Natural Resource Practitioner-in-Residence, 2009
- Alaska Natural Gas Transportation Projects, General Counsel and Principal Deputy, Office of the Federal Coordinator, 2007
- U.S. Department of the Interior, Washington, D.C. and Denver, CO, Counselor to the Solicitor; Associate Solicitor, Minerals, Energy, Land and Water Resources; & Rocky Mountain Regional Solicitor, and Counsel to the Secretary, Assistant Secretaries, Agency Directors and senior leadership on mineral, land, water and energy legal and policy matters, 2002 – 2010
- Snell & Wilmer, LLP, Colorado, Business counsel, litigation services and strategic advice on minerals, environmental, land, tribal, water, endangered species and superfund, 2000 – 2002
- ASARCO Incorporated, Colorado, Associate General Counsel, 1995 – 2000
- ASARCO Incorporated, Colorado, Mining and Environmental Attorney, 1994 – 1995
- Saunders, Snyder, Ross & Dickson, Colorado, Represented mining, manufacturing, and water supply industries in environmental, wetlands/404c veto litigation, natural resource and general law, 1991 – 1994
- Department of the Interior, Washington, DC and Denver, CO, Litigated and counseled on mining, energy, environmental, water and public land law, 1988 – 1991
- Judge Sandstead; Colorado Attorney General-CERCLA litigation unit; National Wildlife Federation; Calkins Kramer; and Holland & Hart, Legal Clerkships, 1984 – 1988
- Thorne Ecological Institute, Boulder, CO, Director of Applied Ecology, 1980 – 1984
- Thorne Ecological Institute, Boulder, CO, President, 1986
- Thorne Ecological Institute, Boulder, CO, Vice President, 1985, 1977 – 1980
- Impact Ltd, Project Manager/Senior Ecologist
- United States Forestry Service, Supervisory Research Forester
- P&M Coal Company, Reclamation Specialist
PROFESSIONAL AFFILIATIONS
- American Bar Association:
- Public Lands and Resources Committee, 2002 – 2004
- Mining Committee, 1999 – 2001
- Mining Committee, Vice Chair, 1997 – 1999
- Water Quality and Wetlands Committee, Chair, 1995 – 1997
- Endangered Species Committee, 1993 – 1997
- Water Quality Committee, 1990 – 1995
- Natural Resources & Environment Journal, Editorial Board, 1988 – 1996
- Colorado Mining Association, Vice Chair, 2000 – 2001
- Colorado Bar Association, Member, Ethics Committee, 1999 – 2000
- Colorado Mining Association, Board of Directors, 1995 – 2000
- Graduate Faculty:
- University of Denver, School of Law, Distinguished Practitioner-in-Residence, 2009
- University of Denver, Environmental Policy and Management, 1992 – 1993
- University of Colorado, Graduate College of Design and Planning, 1981 – 1983
OTHER
Awards:
- Rocky Mountain Mineral Law Foundation, Trustee, 2004 – 2007
- Distinguished Service Award, Yale University, Class of 1980, 2005
- EPA, Environmental Achievement Award, Recipient, 2000
- Thorne Ecological Institute, Environmental Achievement Award, Recipient, 1985
- Wildlife Biologist and Ecologist, Certifications, from Professional Associations
Speaking Engagements:
- NWMA Annual Meeting, Environmental Policy Affecting the Mining Industry and Jobs, Panel Leader, 2011
- AHC Sustainability Annual Workshop, Energy Demand, Hydraulic Fracturing and Risk Management, 2011
- National Association of Environmental Professionals Annual Meeting, AHC Sustainability Annual Workshop, Public Land Access and Renewable Energy Policy, 2011
- NWMA Annual Meeting, Public Land Policy Challenges to Mineral Development, Panel Leader, 2010
- IPAMS Annual Meeting, Government Relations Strategies for Oil & Gas under Obama Policy, 2010
- Annual Environment, Energy and Natural Resource Conference, Colorado Bar, Invited Keynote, 2009
- Energy and Facilities Siting Conference, RMMLF, Co-chair, 2009
- Energy and Facilities Siting Conference, RMMLF, Oil and Gas Development on Public Lands, Law Seminars, Co-Chair, 2010
- CLE International NEPA Conference, Las Vegas, NV, “NEPA, Climate Change and Cumulative Effects – The Tip of the Iceberg”, 2007
- CLE International NEPA Conference, Denver, CO, “NEPA in the Courts – Are Federal Agencies Complying with NEPA?”, 2007
- ABA 14th Annual Meeting, San Diego, CA, “Mining and Environmental Protection on the Public Lands: The Necessary Coexistence of Two National Priorities”, 2006
- CLE International Tenth Annual Conference on the Endangered Species Act, Keynote Speaker, “Messages from the Courts – A 10 Year Perspective on the Endangered Species Act”, 2004
- ABA 12th Annual Meeting, San Antonio, TX, “Agency Action Withheld – The Longstanding APA §706(1) Jurisdictional Rule after SUWA v. Norton”, 2004
Publications:
- “The Renewable Wilderness Resource: Perspectives on the Management of BLM”
- “Interpreting the Unnecessary or Undue Degradation Standard of FLPMA”, Rocky Mountain Mineral Law foundation (RMMLF) Annual Institute, with L. Wenger, 2008
- “Cooperative Conservation: The Federalism Underpinnings to Public Involvement in the Management of Public Lands”, The Byron White Symposium on Constitutional Conflicts on Public Lands, University of Colorado Law Review 75(4): 1133 – 1157, 2004
- ”Wilderness Lands”, RMMLF Special Institute on Natural Resource and Environmental Administrative Law, 2004
- “Mining Law Update”, RMMLF Annual Institute, 2004
- “Natural Resources, Energy and Environmental Law – Year in Review”, Editor and Contributor, Public Lands Chapter, ABA, 2002
- “The Changing Role of Local Influence in Mineral Development, Permitting, and Operations”, RMMLF Annual Institute, with P.V.O’Connor, 2001
- ”Wetlands Primer and Endangered Species Primer”, Lead Editor, Natural Resources and Environment Journal (ABA)
- “Regional Issues in Wetlands Management, Permitting and Mitigation”, Editor, ABA, 1995
- “Overview of Regulations under §404 of the Clean Water Act”, with Jim Sanderson, Wetland Issues in Resources Development in the Western United States, RMMLF Annual Institute, 1993
- “Endangered Species Preservation”, Lead Editor, NR&E Journal, August 1993
- “A Wetlands Primer”, Lead Editor, NR&E Journal, ABA, August 1993
- “Natural Resources, Energy and Environmental Law – Year in Review”, Editor and Contributor, Water Quality Chapter, ABA, 1992 and 1993
- “Natural Resources and Environmental Law — The Tenth Circuit Year in Review 1991”, Co-Author, D.U. Law Review, Summer 1992
- “NEPA Compliance in Oil and Gas Leasing-Segmentation in the Decision to Forgo an Environmental Impact Statement”, University of Colorado Law Review 58(4): 677 – 697, 1988
- “Issues and Technology in the Management of Impacted Western Wildlife (Proceedings)”, Editor and Author, Thorne Ecological Institute, 1982, 1985, 1989, 1991
- “Forgotten Principles of Ecology in the Surface Mining Control and Reclamation Act”, Proceedings, 1981
EDUCATION
J.D., University of Colorado, School of Law
M.F.S. Natural Resource Management & Ecology, Yale University
B.A. Cum Laude Environmental Biology and Conservation, University of Colorado
