Comment: EPA Underground Injection Control Class VI Program Primacy

Greg Upton, Ph.D., LSU Center for Energy Studies

On April 28, 2023, the U.S. Environmental Protection Agency (EPA) opened public comment on a proposal to grant the State of Louisiana’s request for primary responsibility – or primacy – of Class VI wells under the Underground Injection Control Program, which regulates the injection of carbon dioxide into deep rock formation. Class VI injection wells—when used as a part of carbon capture and storage and carbon dioxide removal projects—have the potential to be a critical tool for reducing industrial carbon emissions in Louisiana. 

On June 7, 2023, Center for Energy Studies Interim Executive Director and Associate Professor Greg Upton provided a comment on the implications of decarbonization on the Louisiana and Gulf Coast economy and CCUS specifically. The comment was submitted to the EPA in Docket No. EPA-HQ-OW-2023-0073.

The full comment includes

  • a letter to the EPA from Upton (read the letter);
  • the Center's brief report defining carbon capture, utilization and storage (read the CCUS report); 
  • the Center's white paper titled "The Economic Implications of Carbon Capture and Sequestration for the Gulf Coast Economy" (read the white paper);
  • and the 2023 Gulf Coast Energy Outlook (read the GCEO).