Jim Noe
Partner
Overview
James W. Noe is a government attorney in Holland & Knight's Washington, D.C., and Houston offices, a former co-chair of the Oil and Gas Practice and is currently the professional development chair of Holland & Knight's Energy & Natural Resources Industry Sector Group. In addition, Mr. Noe is currently a vice chair of the American Bar Association's (ABA) Public Lands and Natural Resources Committee. Mr. Noe provides legislative and regulatory advocacy to energy, oil and gas, mining, maritime, construction and other industry clients in a broad range of transactions and disputes. Mr. Noe also has a long history of representing buyers and sellers in complex merger, acquisition and disposition transactions, particularly in the offshore oil and gas industry.
Mr. Noe helps businesses and trade groups address a broad range of energy issues from a governmental relations perspective, as well as confronting regulatory and permitting hurdles, disputes and investigations, especially in the context of energy development on federal lands and waters. He represents companies in investigations conducted by the U.S. Congress or federal agencies, along with enforcement actions brought by various federal agencies, including the U.S. Department of the Interior, U.S. Department of Justice (DOJ), U.S. Coast Guard (USCG) and U.S. Environmental Protection Agency (EPA), relating to alleged regulatory violations that could lead to civil or criminal enforcement action. Mr. Noe regularly challenges federal agency action in administrative and court actions, and he has a substantial practice before the Interior Department's Board of Land Appeals (IBLA) challenging federal energy policies and actions, including actions taken by the Bureau of Safety and Environmental Enforcement (BSEE) and Bureau of Ocean Energy Management (BOEM). He provides effective government relations and lobbying counsel to clients by drawing upon his comprehensive skill set, global business relationships, familiarity with the legislative and regulatory corridors of Washington, D.C., and other national capitals, as well as his work in major commercial and financial centers across Europe, Asia and Africa.
Mr. Noe has extensive experience in oil and gas regulatory matters and regularly represents clients facing legacy liability for decommissioning and environmental remediation in offshore waters and public lands, including in the Gulf of America and Pacific Ocean, as well as in public lands across the western states and on public and private lands in Alaska. He regularly represents oil and gas operators with regulatory compliance issues and operational matters with federal regulatory challenges and issues, including those arising out of the Outer Continental Shelf Lands Act (OCSLA), Coastal Zone Management Act (CZMA), Oil Pollution Act of 1990 (OPA), Clean Water Act (CWA), Endangered Species Act (ESA) and National Environmental Policy Act (NEPA). Mr. Noe also represents energy and mining companies on projects on public lands and offshore waters, including representing companies seeking access to public lands to facilitate large-scale power generation projects supporting data centers and artificial intelligence (AI) facilities.
In addition, dating back to his decades-long career in the upstream oil and gas industry, Mr. Noe has extensive experience acting as lead negotiator and senior attorney in numerous transactions, including multibillion-dollar sales, acquisitions and mergers.
Over the course of his lengthy career, he has personally led and managed hundreds of multinational business formations, corporate launches, investment deals, public offerings, commercial transactions and infrastructure projects around the world.
Among his numerous high-profile engagements was his appointment as primary advocate and spokesman for energy-industry participants following the Macondo (Deepwater Horizon) oil spill. As executive director of the Shallow Water Energy Security Coalition, he testified regularly before U.S. Senate and House committees and held numerous meetings with congressional leaders, White House officials and agency leadership on issues facing exploration and development companies, drilling contractors and oilfield service companies. One of his many accomplishments while serving in this role was to persuade the federal government to end the impasse that had delayed the issuance of new shallow-water drilling permits and had threatened the financial viability of businesses across this vital sector.
Early in his career as a litigator in the oil and gas drilling rig and vessel space, Mr. Noe successfully argued and won numerous cases before state and federal courts, including high-profile shipbuilding disputes heard in the U.S. Court of Federal Claims. After time in private practice, Mr. Noe was named merger and acquisition (M&A) counsel of a French-Dutch offshore oil and gas maritime and technology company based in Monaco, for which he led numerous cross-border business initiatives and acquisitions and dispositions often involving vessels, assets, operations and investments on multiple continents. In this role, Mr. Noe negotiated complex offshore oil and gas field developments projects in South America and West Africa. Subsequently, he joined a leading, public global provider of oil and gas well services, where he served as chief corporate counsel and became a member of the executive management team overseeing matters in more than 140 countries, including significant operations in Latin America, Russia and the former Soviet Union, the Middle East and Asia.
Mr. Noe was one of the original members of the management team of Hercules Offshore Inc., joining as senior vice president, general counsel, chief compliance officer and secretary. In that role, he managed Hercules' initial public offering (IPO) and numerous follow-on offerings and built the public company regulatory and compliance infrastructure. He was the lead negotiator on numerous acquisitions, divestitures and mergers worth billions of dollars cumulatively, including the company's $2.3 billion merger with TODCO. In his role as general counsel, he ensured compliance with U.S. Securities and Exchange Commission (SEC) regulations and was responsible for all regulatory affairs, public relations and risk management. In this role, Mr. Noe conducted numerous compliance investigations and presented investigative findings to various federal agencies, including the DOJ and SEC, related to alleged violations of the Foreign Corrupt Practices Act (FCPA), insider trading and other corporate matters that carried potential civil and criminal liability.
Mr. Noe was also CEO and executive director for CH Offshore Ltd. in Singapore. In that capacity, he managed the public company and its fleet of offshore supply and support vessels operating in Southeast Asia, the Middle East, Africa and Mexico. On behalf of CH's affiliate companies, he oversaw the construction of a fleet of high-specification offshore drilling rigs in Singapore and China. Over the course of his long career, Mr. Noe has served on the board of directors of companies in the U.S., Norway, Luxemburg and Australia in the oil and gas and maritime industries.
Representative Experience
- Represents two of the world's largest multinational oil and gas companies, including a Fortune 5 and Fortune 10 company, on complex transactional and regulatory compliance matters involving:
- pioneering offshore asset retirement and decommissioning strategies, protecting multibillion-dollar asset portfolios while managing multibillion-dollar liabilities
- establishing compliance frameworks under the Oil Pollution Act of 1990 (OPA) and Clean Water Act (CWA)
- advising on operational oversight and monitoring protocols under federal offshore oil and gas regulations to ensure regulatory compliance and environmental stewardship
- Represented an offshore energy trade association to advocate for mandatory leasing provisions for energy projects in offshore waters
- Represents a natural gas and solar energy generation company developing artificial intelligence (AI) and data centers on private and public lands in Texas and California
- Represents an independent exploration and production (E&P) company in criminal defense action before the U.S. Department of the Interior and S. Department of Justice (DOJ)
- Represents an independent E&P company in criminal defense action in the U.S. District Court for the Eastern District of Louisiana
- Represents a large independent E&P company in appealing numerous Incidents of Non-Compliance (INCs) issued by the Bureau of Safety and Environmental Enforcement (BSEE)
- Represents a trade association made up of independent oil and gas companies seeking access to federal offshore leases and sensible oil and gas regulations
- Represents a group of oil and gas companies advocating for the expansion of the Rigs-to-Reef (RTR) program, which allows oil and gas companies to donate retired platforms and offshore infrastructure to coastal states for use as marine habitats
- Represented an independent E&P company in the reefing of one of the largest structures installed in federal waters as a part of the RTR program
- Advises the executive leadership of a large private equity firm on energy policy issues and political developments impacting the energy sector
- Represented a major oil and gas company regarding potential civil and criminal liability related to potential violation of Interior Department regulations
- Provided crisis management and media advice to a large independent E&P company related to an oil spill
- Represented a large E&P company in advocating and obtaining Suspension of Production (SOP) from the BSEE
- Represented a large E&P company before the U.S. Department of Defense and Interior Department following the client's discovery of World War II-era unexploded munitions on an offshore oil and gas property
- Represents a large independent exploration and production (E&P) company in a large divestiture of oil and gas properties
- Represented a national oil company in the purchase of working interest of offshore blocks in Ghana in West Africa
- Represented a Singapore company in the acquisition of offshore oil and gas properties in Australia
- Represented a large independent offshore E&P company as regulatory counsel before the U.S. Department of the Interior and U.S. Department of Justice (DOJ) in Chapter 11 bankruptcy proceeding, which involved various disposition and merger transactions
- Represents a group of oil and gas companies seeking constructive amendments to financial assurance regulations and bonding requirements to cover decommissioning liability
- Represented an international oil and gas company in the acquisition of deep-water offshore oil and gas properties in the Gulf of Mexico
- Represented a large independent E&P company in the acquisition of a wireline company and marine assets
- Represented a large independent E&P company in a large divestiture and related Israeli high-yield bond transaction
- Represented a U.S. oilfield services company in the purchase of a manufacturing facility and business in India
- Represented a U.S. maritime company in the disposition of a fleet of drilling rigs and associated maritime assets to a Nigerian E&P company
- Represents Chapter 11 bankruptcy plan administrator for a former offshore exploration company in various wind-down dispositions
- Represents U.S. hedge fund evaluating renewable and next-generation energy projects, including clean hydrogen projects and emerging nuclear fusion technologies
Credentials
- Louisiana State University, Paul M. Hebert Law Center, J.D.
- The University of Alabama, B.A., Criminal Justice and Sociology, with honors
- District of Columbia
- Louisiana
- Texas
- U.S. Supreme Court
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Court of Appeals for the Federal Circuit
- U.S. District Court for the Eastern District of Louisiana
- U.S. District Court for the Middle District of Louisiana
- U.S. District Court for the Western District of Louisiana
- U.S. District Court for the Southern District of Texas
- Kato Energy Pty Ltd., Director, 2018-Present
- Louisiana State University, John P. Laborde Energy Law Center Advisory Council, 2012-Present
- University of Alabama, College of Arts and Sciences, Leadership Board of Directors, 2012-Present
- International Association of Drilling Contractors (IADC), Ethics and Compliance Committee, 2006-2014
- The Legal 500 USA, Energy Transactions: Oil and Gas, 2025
- Leading Energy Lawyers, Lawdragon 500, 2025
- Up and Comer, Houston Business Journal, Best Corporate Counsel, 2007