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On June 17, the Environmental Protection Agency (EPA) published a proposed rule to approve Texas’s application for primary permitting and enforcement responsibility (primacy) for carbon dioxide (CO2) sequestration wells...more
The proposal could accelerate the permitting process for carbon capture and storage projects in the state. On June 9, 2025, the US Environmental Protection Agency (EPA) signed a proposed rule that, if approved, would...more
This week, the U.S. Environmental Protection Agency (EPA) took the penultimate step to granting Texas the authority to directly issue Class VI permits under the Safe Drinking Water Act’s Underground Injection Control (UIC)...more
On June 9, 2025, the U.S. Environmental Protection Agency (EPA) proposed granting the State of Texas primary enforcement authority—commonly referred to as “primacy”—over the permitting and regulation of Class VI underground...more
On June 9, 2025, EPA issued a prepublication version of the proposed rule granting Class VI underground injection control (“UIC”) primary enforcement authority (“primacy”) to Texas. Class VI UIC wells are used for the...more
The proposal could accelerate the permitting process for projects in the state, including carbon capture and storage (CCS) projects....more
Stakeholders following developments in states obtaining primary authority for implementation and enforcement of permitting of carbon storage and sequestration wells, take notice. With a recent Memorandum of Agreement between...more
This alert was originally published on September 19, 2024, and has been revised based on recent developments. Update: On April 29, 2025, US EPA and the Texas Railroad Commission (RRC) signed a memorandum of agreement...more
Developing a carbon sequestration project requires multiple technical disciplines, excellent project management skills, and the ability to adapt the technical work processes to the unique aspects of the specific project....more