Class VI Permit Tracker

Established as part of the Safe Drinking Water Act (SDWA) of 1974, the Underground Injection Control (UIC) program classifies injection wells into multiple classes. Class VI wells, which are used to inject carbon dioxide into deep rock formations, are subject to a stringent, multi-step permitting process. The Environmental Protection Agency (EPA) offers an online permit tracking dashboard that shares timely information about Class VI permit applications.

Steps in the Class VI Permitting Process

According to the EPA, obtaining a Class VI permit is a five-step process that generally takes about 24 months.

1. Completeness review in which the EPA verifies that an application contains all required information. Although this stage typically takes 30 days, receiving a “Notice of Deficiency” (NOD) may cause permitting delays. Developers should carefully review the EPA’s Class VI Permit Application Completeness Checklist prior to submitting applications.

2. Technical review commences after the EPA determines that an application has been properly completed. This phase usually involves the most amount of time, as all application materials must be reviewed in detail. Applicants who receive a “Request for Additional Information” (RAI) must respond within 30 days (or request a different timeline).

3. Draft permit preparation occurs when a well passes the technical review phase. A draft permit specifies conditions under which a well would be permitted to operate.

4. Public comment allows interested stakeholders to review and share feedback about the proposed CO2 project. In some cases, hearings are requested by the public.

5. Final permit preparation occurs after public comment and enables applicants to commence well construction or conversion.

Current Class VI permit applications are listed on the Class VI Permit Tracker. Note that some states, such as Arizona and Texas, have been granted “primacy” for Class VI injection wells. Projects in these states are not tracked on the EPA’s webpage. Louisiana, for example, maintains its own permit and application tracking page.

Data & Metrics on the UIC Class VI Permit Tracker

The UIC Class VI Permit Tracker offers a variety of summary, review phase, and project-specific insights, all of which are available to the public. Examples include:

Summary Metrics

●     Number of projects and well applications currently under review

●     Number of final permitting decisions issued

●     Percentage of applications received in the last twelve months

●     Number of applications that are pending an applicant’s response

●     Number of applications on hold as requested by the applicant

Review Phase Metrics

Number of well applications in the following phases:

●     Completeness review

●     Technical review

●     Prepare draft permit

●     Public comment

●     Final permit decision

Project-Specific Insights

●     Each project’s current status

●     Estimated date of permit decision

●     Number of days “waiting on applicant” by phase

Land Services for Class VI Injection Well Projects

Trigen has first-hand experience with Class VI injection well projects. Partner with us to keep your project on track. Let us handle your pore space rights acquisition, Class VI well surface rights acquisition, pipeline right of way, and stakeholder engagement.

Contact us to learn about our land services for CCS.