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LWF Comments on Louisiana’s Application for Primacy to Permit Class VI Wells

You can read Louisiana Wildlife Federation’s full comments to the US EPA about the State of Louisiana’s application for primacy in Class VI permitting HERE.

With certain qualifications related to the State’s ability to deploy an effective expanded Underground Injection Control Program (UIC) to administer, implement, and enforce the federal Safe Drinking Water Act (SDWA) as it relates to Class VI injection wells, then, LWF supports the State of Louisiana’s application for primacy.

First and foremost, LWF shares the belief that a state’s UIC program must meet strict safeguards when considering a Class VI well permit application to ensure protection of the public’s drinking water including requiring applicants have:

  • Operating requirements to ensure the injection activity will not endanger USDWs or human health.
  • Financial assurance mechanisms sufficient to cover the cost for all phases of the geologic sequestration project including the post injection site care period and until site closure has been approved by the permitting authority.
  • Emergency and remedial response plans.
  • Reporting of all testing and monitoring results to the permitting authority to ensure the well is operating in compliance with all permit and regulatory requirements.

To the extent the USEPA is evaluating the State of Louisiana’s application with these priorities in mind, LWF supports the primacy request of the State.

We further affirm that carbon capture, utilization and storage (CCUS) may be an effective process when properly regulated and monitored for potential adverse impacts on the public and its drinking water.  However, Louisiana’s past experience with industrial development, including abandoned oil and gas wells and coastal damage from energy development and pipeline activities, gives rise to concerns that the State may not adequately administer and enforce the UIC program’s laws and regulations, particularly as they relate to holding applicants accountable for the impact of their drilling.

The letter further provides LWF’s main concerns about:

  • environmental justice
  • siting
  • public input and engagement
  • staffing
  • application transparency
  • evaluating Louisiana’s performance

You can still provide your own comments to the proposed rule by going to the EPA webiste and submiting comments there by July 3, 2023. Let your voice be heard on this important issue for Louisiana’s energy and industrial future.


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