News & Analysis as of

Permits Underground Injection Wells Environmental Protection Agency (EPA)

King & Spalding

Developments in Class VI Delegation: Arizona and Texas Await Final Rules

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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

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

Evaluation of the EPA's Implementation of the Underground Injection Control Class VI Well Program: EPA Office of Inspector General...

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a July 28th report titled: Evaluation of the EPA’s Implementation of the Underground Injection Control Class VI Well...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

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

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

Holland & Knight LLP on

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

ArentFox Schiff

Illinois Passes Comprehensive Law Governing Carbon Capture, Utilization and Sequestration Projects in Illinois

ArentFox Schiff on

On May 26, the Illinois legislature passed comprehensive carbon capture, utilization, and sequestration (CCUS) legislation. CCUS involves the capture of carbon dioxide directly from ambient air or uses processes to separate...more

Mayer Brown

State of Louisiana Granted Primacy Over Class VI Wells

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Executive Summary - The State of Louisiana recently achieved a significant milestone in the regulation of the carbon capture and sequestration (CCS) industry by obtaining primary enforcement authority (primacy) over Class...more

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

Carbon Sequestration/Class VI Underground Injection: U.S. EPA Environmental Appeals Board Petition Challenging Two Indiana Permits

Four individuals filed a February 22nd document before the United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) styled: Petition for Review by Andrew Lenderman, Ben Lenderman, Floyd...more

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

Underground Injection Control/Class II-D: Three Rivers Waterkeeper U.S. EPA Environmental Appeals Board Challenge to Allegheny...

Protect PT and Three Rivers Waterkeeper (collectively, “Three Rivers”) filed a document before the United States Environmental Protection Agency (“EPA”) Environmental Appeals Board styled: Petition for Review by Protect...more

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

Underground Injection Control/California Power Generation Plant: U.S. EPA Environmental Appeals Board Petition for Review

Panoche Energy Center, LLC, (“PEC”) filed an October 28th Petition for Review (“Petition”) before the United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) challenging certain conditions of...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,...

U.S. EPA Environmental Appeals Board: Petition Filed Challenging Class III/Class V Underground Injection Permits for South Dakota...

The Oglala Sioux Tribe (“Petitioner”) filed a December 24th Petition for Review (“Petition”) challenging the United States Environmental Protection Agency’s (“EPA”) issuance of an underground injection control (“UIC”) Class...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

Sheppard Mullin Richter & Hampton LLP

After 9th Circuit Ruling in Hawai‘i Wildlife Fund v. County of Maui, EPA Considers ‘Clarifying’ Clean Water Act Coverage for...

A recent Ninth Circuit ruling that pollutants reaching waters of the United States through groundwater may trigger Clean Water Act liability has prompted the U.S. EPA to consider clarifying its position on the subject. The...more

Eversheds Sutherland (US) LLP

New Source Review Update: Courts Limit Aggregation for Major Source Determination and Challenges to NSR Pre-Project Emissions...

Pennsylvania Court Limits NSR Permit Aggregation - In February, the Middle District of Pennsylvania struck down an environmental group’s challenge that Ultra Resources should have aggregated eight compressor stations...more

McAfee & Taft

Envirnomental Regulatory Update: Environmental Progress & Sustainable Energy - Volume 32, Issue 3 - October 2013

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Oil and Gas Update - Hydraulic Fracturing Regulations - Bureau of Land Management: On May 16, 2013, the U.S. Department of Interior’s Bureau of Land Management (BLM) released a Supplemental Notice of Proposed...more

Clark Hill PLC

Developing Geothermal Power Generation Facilities in Arizona: "How Many Permits?"

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The development of Arizona's geothermal energy resources has the potential to provide industrial and commercial projects with a constant, renewable source of electrical power. Research conducted to date demonstrates some...more

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