News & Analysis as of

State and Local Government Carbon Capture and Sequestration Permits

Troutman Pepper Locke

Well, Well: Outlook for CCUS Projects in Texas Improves as EPA Proposes to Delegate Permitting Authority and the Texas Supreme...

Troutman Pepper Locke on

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

Latham & Watkins LLP

EPA Proposes Granting Texas Primacy for Class VI Wells

Latham & Watkins LLP on

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

Vinson & Elkins LLP

Texas Progresses Toward CCS Primacy

Vinson & Elkins LLP on

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

Pillsbury - Gravel2Gavel Construction & Real...

Texas Clears Penultimate Hurdle to Class VI Primacy: What it Means for CCS and State-Led Permitting

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

Baker Botts L.L.P.

Carbon Sequestration Advances in Texas as EPA Proposes to Grant Class VI Primacy

Baker Botts L.L.P. on

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

Latham & Watkins LLP

EPA Proposes Granting Arizona Primacy for All Classes of Injection Wells

Latham & Watkins LLP on

The proposal could accelerate the permitting process for projects in the state, including carbon capture and storage (CCS) projects....more

Perkins Coie

State Control of Injection Well Permitting Stays in Focus Amid Legal Challenges Over CCS Infrastructure

Perkins Coie on

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

Beveridge & Diamond PC

Carbon Sequestration in Texas: EPA Region 6 Issues Draft Permits for Proposed Geologic Sequestration of Carbon Dioxide in Texas...

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

Steptoe & Johnson PLLC

U.S. EPA Approves West Virginia’s Request for Primacy Regarding Issuance of Class VI Injection Well Permits

Steptoe & Johnson PLLC on

The U.S. Environmental Protection Agency (EPA) has approved West Virginia’s application to obtain authorization and primacy regarding the issuance of permits for Class VI underground injection control (UIC) wells. This...more

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