CCUS: Understanding The Class VI Permitting Process
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
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 December 28, 2023, the U.S. Environmental Protection Agency (“EPA”) granted Louisiana primary enforcement authority (“primacy”) under the federal Safe Drinking Water Act’s (“SDWA”) Underground Injection Control (“UIC”)...more
EPA’s transfer of primary enforcement authority to states for carbon capture and storage projects may decrease permitting delays but raise legal questions. Louisiana has become the third state in the United States to...more
Recently, the United States Environmental Protection Agency ("EPA") signed a final rule granting the State of Louisiana's request for primary responsibility for the permitting, compliance, and enforcement of Class VI (deep...more