CCUS: Understanding The Class VI Permitting Process
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
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
The U.S. Environmental Protection Agency (“EPA”) recently announced that it will be taking a hard look at the Texas Railroad Commission’s (“RRC”) enforcement of injection well regulatory practices (or the lack thereof). The...more
In furtherance of the U.S. Environmental Protection Agency’s PFAS Strategic Roadmap, which our firm has written about frequently, the EPA released an updated guide on destroying and disposing of PFAS....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
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
The United States Environmental Protection Agency (“EPA”) and Sterling Operators, Inc., (“Sterling”) entered into a July 16th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Safe Drinking Water...more
ANNOUNCEMENTS - Air - Stakeholder Input Requested on Potential New Rules - Affordable Clean Energy (ACE) Program Rules: Ohio EPA is requesting stakeholder input on potential new rules in the Ohio Administrative Code...more
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
The Borough of Plum, Pennsylvania (“Plum”) filed an April 2nd Petition for Review (“Petition”) before the United States Environmental Protection Agency (“EPA”) Appeals Board (“EAB”) of a UIC Class II-D Permit (“Permit”)...more
A lawsuit seeking an immediate halt to oil and gas wastewater injection at 2,500 wells across California took a positive turn for energy producers last week as Superior Court Judge George C. Hernandez denied plaintiffs’...more
On Tuesday, March 3, twelve underground injection control (“UIC”) wells in California’s Central Valley, specifically in Kern County, were shut down in order to protect subsurface drinking water from potential contamination. ...more
California Assemblymember Das Williams (D-Carpinteria) has introduced an oil and gas bill to ensure that the state comes into compliance with the Class II underground injection (“UIC”) requirements under the federal Safe...more
On Friday, July 18, 2014, the Department of Conservation’s Division of Oil, Gas and Geothermal Resources (“DOGGR”) announced that it will review California’s Underground Injection Control (“UIC”) Program to ensure compliance...more