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CCUS: Understanding The Class VI Permitting Process
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Carbon Capture, Use, and Sequestration (CCUS) Webinar
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North Dakota surface owners defeated the carbon-storage lobby’s effort to steal their interstices.* In Northwest Landowners Association, et al, v. State of North Dakota et al, a district court declared a portion of the CO2...more
As energy infrastructure projects ramp up along the U.S. Gulf Coast and beyond, the role of states in holding primary enforcement authority (“primacy”) for certain federal programs has taken center stage; this is particularly...more
The EPA’s November 2025 approval granting Texas primary enforcement authority over Class VI injection wells fundamentally changes who controls permitting of carbon capture and sequestration projects across the nation’s...more
The U.S. Environmental Protection Agency (EPA) issued a final rule approving the Texas Railroad Commission’s (RRC) application for primacy over Class VI injection wells. Class VI is a category of Underground Injection Control...more
In the context of regulating the Future Fuel Law (Law No. 14,933/2024), the Ministry of Mines and Energy (MME) launched, on November 17, 2025, Public Consultation No. 205, concerning the draft Decree that regulates Carbon...more
On November 12, 2025, the U.S. Environmental Protection Agency (EPA) approved Texas’s request for primacy over Class VI underground injection control (UIC) wells under the Safe Drinking Water Act, authorizing the Railroad...more
Last week, the U.S. Environmental Protection Agency (EPA) announced that it will formally grant the Railroad Commission of Texas (RRC) primary authority (known as “primacy”) to administer the Class VI Underground Injection...more
The rule positions the Railroad Commission of Texas as the primary permitting authority over Class VI wells and could expedite CCS projects in the state....more
On November 7, 2025, Environmental Protection Agency (EPA) Administrator Lee M. Zeldin signed a final rule approving the application of the State of Texas for transfer of primacy over Class VI Underground Injection Control...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
The U.S. Environmental Protection Agency (EPA) on Nov. 12, 2025, announced a final rule granting the State of Texas primary implementation and enforcement authority (also known as primacy) for Class VI Underground Injection...more
The agency’s actions have significant implications for the domestic carbon capture and storage industry. In the same week, the US Environmental Protection Agency (EPA) took two rulemaking actions with significant...more
On September 10, 2025, the U.S. Environmental Protection Agency (EPA) announced a final rule granting Arizona primacy to administer all classes of underground injection wells under the Safe Drinking Water Act (SDWA). This...more
The Department of Energy (DOE) has recently terminated or suspended a number of high-profile energy grants, withdrawing more than $3.7 billion in commitments for projects involving carbon capture, decarbonization, and...more
On August 1, EPA’s comment period on its proposal to grant Texas “primacy” over permitting and enforcement of Class VI underground injection wells closed, marking another milestone in the expansion of state-managed Carbon...more
In a significant move for environmental policy and energy innovation, the U.S. Environmental Protection Agency (EPA) has proposed to approve Texas’ application to administer its own Class VI underground injection well...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
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
Key Takeaways - - EPA is evaluating the Texas Railroad Commission's formal primacy application. If granted, Texas will assume primary enforcement authority—or primacy—over Class VI wells. - Carbon capture and storage...more
The Ohio General Assembly has recently introduced their attempt to allow carbon capture and sequestration (hereinafter “CCS”) as a widespread means of reducing carbon emissions within the State. The proposed act (hereinafter...more
Supreme Court restricts EPA's authority to mandate carbon emissions reductions - Associated Press - June 30 - In a blow to the fight against climate change, the Supreme Court on Thursday limited the extent of the U.S....more