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Clifford Chance

Clifford Chance
Briefings

Briefings

Progress on UIC Class VI Primacy: EPA and Texas Railroad Commission Sign Memorandum of Agreement

May 22, 2025

On April 29, 2025, the U.S. Environmental Protection Agency signed a Memorandum of Agreement with the Texas Railroad Commission, a major step towards granting Texas primacy for regulation of Class VI underground injection control carbon capture and sequestration wells. The MOA, and EPA's preparation of a proposed rulemaking approving the RRC's primacy application, indicate the possibility that Texas may receive Class VI primacy by the end of 2025.

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