By: Tariq Siddiqui
The Gulf Coast region is experiencing a significant surge in Carbon Capture and Storage (CCS) projects, with 121 Class VI permit applications already filed—76 in Louisiana and 45 in Texas—underscoring the growing opportunities in this space. Class VI well permits, which are issued for the entire lifecycle of an injection well—from initial injection authorization to site closure, often spanning decades—require a more thorough, upfront planning process compared to other well classes. With no periodic re-application required, timely and efficient permitting is crucial for maximizing the value of these projects. Avoiding delays in the Class VI permitting process is not just a regulatory necessity; it's essential for ensuring that CCS initiatives meet their ambitious timelines and contribute to the region's energy transition goals.
1 - Project Plans Must be Reviewed Periodically - Misalignment Cause Delays
Owners and operators are required to develop and submit five essential project plans as part of the permit application, which must be reviewed, approved, and periodically updated throughout the project's life. Ensuring these plans are aligned with evolving site conditions is critical, as any significant changes can trigger delays in the approval process and operational start. In this article, we'll explore key strategies for streamlining the Class VI permitting process and minimizing the risk of costly delays and setbacks. The 5 plans are:
Area of Review (AoR) and Corrective Action Plan
Testing and Monitoring Plan
Injection Well Plugging Plan
Post-Injection Site Care (PISC) and Site Closure Plan
Emergency and Remedial Response Plan
2 - Robust & Early Data Collection Is Key - Avoids Delays
These plans are developed iteratively, starting with preliminary data from the pre-permitting phase during initial characterization and refined as more site-specific data (logging, coring, sampling and testing) is collected from injection well in pre-operation phase and integrated in final site characterization. The EPA/UIC expects that final reservoir characterization and AoR must be closely aligned with the initial predictions, as significant deviations could trigger permit modification, leading to approval delays.
The Application Review Process: The Class VI permit application review by EPA/UIC includes three phases:
Data Completeness Review
Detailed Technical Review
Public Comment and Feedback Period
If there are substantial changes in the Area of Review (AoR) after final reservoir characterization, the permit may need to be modified, potentially restarting the public notice process and delaying permitting and injection operations. Strategic planning and following tips can help alignment in initial and final AoR, thus avoiding any delays.
3 - Six Tips for Avoiding Delays & Permit Modifications:
Allocate the right technical resources with relevant expertise early in project.
Ensure complete data is submitted (avoid recycling during completeness review).
Collect new and site-specific data (e.g., 2D/3D seismic, startigraphic-well etc), to supplement legacy data in the area.
Gather comprehensive site-specific data, including multi-flow parameters (e.g., capillary pressures, relative permeability).
Tailor activities to the specific project—don’t settle for the minimum requirements (ex: inadequate number of monitoring locations or frequency of reevaluation of AoR) .
Align project plan updates with AoR revaluation, especially during early injection years (more frequent reevaluations in early years - not just once every 5 years.)
By proactively planning and collecting the right data, operators can reduce the risk of misalignments in initial and final charaterization and significant differences in AoR that results in delays and permit modifications, ensuring smoother operations throughout the life of the project.
The UEPA : Navigating CCS Complexity for Client Success
For your next CCUS project, trust the expertise of UEPA. With our in-depth knowledge of CCS project development, we offer precise and efficient support for your project. Our comprehensive services cover the full lifecycle of project development and reservoir characterization, ensuring successful Class VI permit applications. Partner with UEPA to ensure your CCUS project is executed smoothly and sustainably.