News & Analysis as of

Oil & Gas Permits Environmental Protection Agency (EPA)

Beveridge & Diamond PC

Emerging Developments in the Treatment and Beneficial Use of Produced Water in Texas

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Key Developments - At the end of the legislative session, Texas Governor Greg Abbott signed House Bill 49, limiting tort actions relating to the beneficial use of produced water, a byproduct of oil and gas extraction....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Section 401/Clean Water Act: Energy Marketers of America (formerly PAA) EPA Requests for Comments Addressing Implementation

The trade association Energy Marketers of America (“EMA”) (formerly, Petroleum Association of America) submitted August 6 comments to the United States Environmental Protection Agency (“EPA”) addressing: Establishment of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Title V/Clean Air Act: Center for Biological Diversity Petition to Object Addressing Weld County, Colorado Oil and Gas Production...

The Center for Biological Diversity (“CBD”) filed a June 27th Title V Petition to Object (“Petition”) before the Administrator of the United States Environmental Protection Agency ("EPA”) related to the Anschutz Equus Farms...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Underground Injection Control: U.S. EPA Environmental Appeals Board Petition for Review Filed Challenging Three Michigan Brine...

Flow Water Advocates (“FWA”) filed a pleading before the United States Environmental Protection Agency (“EPA”) Environmental Appeals Board styled: PETITION FOR REVIEW OF UNDERGROUND INJECTION CONTROL PERMITS ISSUED AND...more

Troutman Pepper Locke

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

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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

Latham & Watkins LLP

EPA Proposes Granting Texas Primacy for Class VI Wells

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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

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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

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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

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

Holland & Knight LLP

The Path to Class VI Primacy in Texas: MOA Reveals State and Federal Priorities for Program

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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

Mitchell, Williams, Selig, Gates & Woodyard,...

Title V/Clean Air Act: Center for Biological Diversity Petition to Object Filed Addressing Garfield County, Colorado Compressor...

The Center for Biological Diversity (“CBD”) filed a May 8th Clean Air Act Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) relating to Bargath, LLC for the Hyrup...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

Mitchell, Williams, Selig, Gates & Woodyard,...

Title V/Clean Air Act: Center for Biological Diversity Petition to Object Filed Addressing Weld County, Colorado Compressor...

The Center for Biological Diversity (“CBD”) filed an April 3rd Clean Air Act Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) related to DC Operating Company, LP for the...more

Fox Rothschild LLP

President Trump's New EPA Administrator Unveils Agency's New Priorities

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Amid uncertainty over future staffing and funding levels, Environmental Protection Agency (EPA) Administrator Lee Zeldin announced a new priority list for the agency titled the “Powering the Great American Comeback...more

Holland & Knight LLP

EPA Issues Final Methane Regulations for New and Existing Sources

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The U.S. Environmental Protection Agency (EPA) announced its final rule on Dec. 2, 2023, to sharply reduce emissions of methane and other air pollution from oil and natural gas operations. The final action, which is more than...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Title V Objection/Clean Air Act: WildEarth Guardians Petition Addressing New Mexico Oil/Gas Processing Facility

WildEarth Guardians filed a September 26th Petition (“Petition”) requesting that the United States Environmental Protection Agency (“EPA”) Administrator object to the initial Clean Air Act Title V Operating Permit for the...more

Opportune LLP

Navigating The Class VI Injection Permit Process For Carbon Sequestration

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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

Mitchell, Williams, Selig, Gates & Woodyard,...

Refinery Reactivation: Petition Before the U.S. EPA Environmental Appeals Board Challenging Plantwide Applicability Limit Air...

The Center for Biological Diversity (“CBD”), other organizations, and an individual submitted a February 3rd Petition for Review (“Petition”) before the United States Environmental Protection Agency (“EPA”) Environmental...more

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights: Issue 35, September 2020

U.S. Shale Producers Race for Federal Permits Ahead of Presidential Election - "Federal permitting in the largest U.S. oilfield in the Permian Basin, located in Texas and New Mexico, is up 80 percent in about the last three...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Natural Gas Compressor Station/Title V Permit: U.S. EPA Environmental Appeals Board Addresses Challenge to NESHAP Permit Condition

The United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) addressed in a September 2nd Order a Petition filed by MPLX challenging a permit condition that the federal agency placed in a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Citizen Suit Action/Clean Air Act: Sierra Club Judicial Action Challenging Colorado Department of Public Health and Environment...

The Center for Biological Diversity and Sierra Club (collectively “Sierra Club”) filed a Complaint in District Court (Adams County, Colorado) challenging the Colorado Department of Public Health and Environment, Air Pollution...more

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights - February 2020 #4

Cancelled Teck Oil Sands Project Underscores Global Climate-Energy Policy Tension - "The Frontier project became the latest casualty in oil-producing countries with robust environmental movements agitating to cut...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Brine Injection/UIC: U.S. EPA Environmental Appeals Board Addresses Challenges to Class II Permit

The United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) addressed in an August 8th Order challenges to an Underground Injection Control (“UIC”) Class II Permit (“Permit”) issued by the...more

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights - June 2019 #4

Analysts Say U.S. Coal Merger Not Anti-Competitive- "The proposed 'extraordinary' joint venture between U.S. coal majors Peabody Energy and Arch Coal will be structurally beneficial, rather than anti-competitive for U.S....more

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