Priscilla (Polly) E. Hampton

Areas of Emphasis

Polly Hampton is a shareholder in the Environmental Group of Babst Calland. Ms. Hampton’s practice focuses on contaminated site cleanups, brownfield redevelopment, and environmental diligence and risk management in mergers and acquisitions. She counsels a range of businesses—from mining, manufacturing, and energy to real estate and project developers—on remediation, permitting, compliance, and enforcement matters under federal and state environmental laws.

Ms. Hampton addresses the “dirty dirt” aspect of deals and projects, counseling on the identification, management, and cleanup of hazardous substances and allocation of related liability. She represents clients in defense of government enforcement and cleanup actions, and she has achieved favorable outcomes for clients facing potential natural resource damages liability. She also oversees internal environmental compliance audits both in the regular course of business and as part of transaction-related environmental due diligence, working with businesses to identify and correct potential deficiencies before and after closing.

Ms. Hampton provides pragmatic solutions reflective of her clients’ risk tolerance, and project developers appreciate her deft approach to tackling environmental issues that threaten to derail a project or deal. She routinely counsels manufacturing facilities, energy infrastructure companies, and natural resource developers on various issues involving hazardous substance releases, management of hazardous and solid waste, industrial wastewater and stormwater management, and air emissions.

A veteran and former U.S. Navy Surface Warfare Officer, Ms. Hampton helped found Women in Environment, an organization aimed at furthering professional development opportunities for women in the environmental field.

Representative Matters

Complex Sediment Site Remediation

  • Lead counsel to largest terminal operator in North America on all aspects of Portland Harbor Superfund Site (Portland, OR), including multi-party allocation proceeding, remediation counseling, enforcement defense and settlement strategies.
  • Counsel to U.S. shipbuilding company at Gowanus Canal Superfund Site (New York, NY) to advise on multi-party allocation proceeding and related settlement.
  • Advise former paper mill operator at Kalamazoo River Superfund Site (Kalamazoo, MI) in settlement negotiations, site remediation and natural resource damages defense.

Enforcement Defense

  • Defend multinational natural resource company in defense of EPA Region 10 enforcement action involving alleged mismanagement of mine and laboratory waste at remote mining operation in Northwest Alaska.
  • Defend shipping port terminal operator in Portland, OR against Clean Water Act citizen suit involving alleged stormwater permit violations.

Transaction Counseling

  • Counseled global logistics company in assessing compliance with and risks related to RCRA generator requirements for reverse logistics business target with facilities in multiple U.S. jurisdictions.
  • Advised energy project developer on environmental diligence, risk management and contracting related to acquisition of former coal-fired power plant property in Maryland for Battery Energy Storage System (BESS) site development.
  • Represented numerous private equity and other clients in environmental due diligence and other environmental matters associated with acquisition, sale, investment and financing transactions, including commissioning and review of Phase 1 and Phase 2 environmental site assessments, negotiating transactions, transferring facility permits, and managing environmental risk.
  • Counsel to Chicago-based real estate developer on cost recovery and settlement strategy following acquisition of property contaminated with leaking underground storage tanks.

Project Development

  • Environmental counsel to Utah transportation agency heading urban rail expansion project involving legacy contamination and related risk management in contracting.
  • Environmental counsel to joint venture seeking to develop nationwide network of EV charging stations, or “rechargeries,” including real property transactions involving legacy site contamination, brownfields reuse and post-closing remediation planning.

Compliance and Permitting

  • Lead counsel to multinational resource company on all aspects of environmental compliance and permitting (wetlands, wastewater, water rights, dangerous/hazardous waste, and site remediation) during post-closure care and reclamation of hard rock mine in Eastern Washington.
  • Advised mining and construction parts manufacturer in decommissioning steel foundry in Portland, OR, including environmental compliance and permitting during plant shut-down, decommissioning, demolition, site investigation and planning for reuse in urban environment.
  • Advised hard rock mine in Northwest Alaska on various compliance programs including dust management and related air emissions, site remediation, material site reclamation, water line permitting, stormwater management, and hazardous waste management.
Background

Ms. Hampton earned her B.A. in 1998 from Stanford University. She received her J.D. from the State University of New York at Buffalo Law School in 2008, summa cum laude, where she interned for the Honorable Marjorie O. Rendell, United States Court of Appeals for the Third Judicial Circuit.

Memberships and Affiliations

Ms. Hampton is admitted to practice in New York and Oregon, and before the U.S. Court of Appeals for Veterans Claims and U.S. District Court for the District of Oregon.  She is a Court Appointed Special Advocate for CASA of Chautauqua County, serves as President of the YWCA Jamestown and is a Mentor of Chautauqua Striders.

Since 2017, Ms. Hampton has been ranked among Oregon’s top environmental lawyers in Chambers and Partners’ Chambers USA Guide. She was also named the 2015 “Women of Vision” by the Portland Oregon Daily Journal of Commerce.