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How to Fast-Track Class VI Permitting: Six Tips To Avoid Delays

AMBITIOUS TIMELINES REQUIRE AVOIDING DELAYS

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.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.

PERMIT MODIFICATION CAUSES DELAYS

Five plans are required for Class VI permit applications (see list in the article) that are reviewed by EPA/UIC. These plans are developed iteratively, starting with preliminary data from the pre-permitting phase and refined as more site-specific data (logging, coring, sampling and testing) is collected from injection well in pre-operation phase. The final reservoir characterization and AoR must be closely aligned with the initial predictions, as significant deviations could trigger permit modification, leading to approval delays.

Six Tips for Avoiding Delays & Permit Modifications:
  1. Allocate the right technical resources with relevant expertise early in project.

  2. Ensure complete data is submitted (avoid recycling during completeness review).

  3. Collect new and  site-specific data (e.g., 2D/3D seismic, startigraphic-well etc), to supplement legacy data in the area.

  4. Gather comprehensive site-specific data, including multi-flow parameters (e.g., capillary pressures, relative permeability).

  5. 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) .

  6. Align project plan updates with AoR revaluation, especially during early injection years (more frequent reevaluations in early years - not just once every 5 years.)

WAY FORWARD

By proactively planning and collecting the right data, operators can reduce the risk of delays and permit modifications, ensuring smoother operations throughout the life of the project.