Frequently Asked Questions | Colorado Energy & Carbon Management Commission

What are injection wells?

An injection well is used to place fluid underground into porous geologic formations. The Underground Injection Control (UIC) program consists of six classes of injection wells. Each well class is based on the type and depth of the injection activity relative to an Underground Source of Drinking Water (USDW). The UIC program protects USDWs from endangerment by setting minimum requirements for injection wells.

Injection well classes are overseen by either a state, tribal agency, or EPA regional office. States and tributes may apply for primary enforcement authority (primacy) to implement the UIC program. Colorado has primacy for Class II injection wells within state boundaries, except for those on Indian lands. Colorado has applied for primacy for Class VI injection wells.

For more information about the Underground Injection Control program, visit the EPA website.

Is Geologic Carbon Sequestration Safe?

Federal and state regulatory frameworks are designed to ensure the safety and long-term security of geologic storage sites. For an in-depth analysis, see our report: Carbon Capture and Storage: Safety and Impact Considerations from Source to Sequestration

How is CO2 monitored once it’s injected underground?

Federal and state regulations include extensive testing and monitoring requirements to monitor the integrity of the injection well, the integrity of other wells such as monitoring wells, groundwater quality, and the movement of the CO2 plume and pressure front. Operators must adhere to these requirements until site closure is authorized. Periodic monitoring will be a component of the long-term stewardship plan for each geologic storage site.

Who is compensated for CO2 injected into the subsurface?

HB24-1346 established that ownership of sequestration estate (the portion of the pore space necessary for geologic storage) is vested in the owner of the overlying surface estate, unless otherwise severed, conveyed, or reserved. Additionally, the commission may hold a hearing and issue an order to unitize one or more geologic storage resources into a geologic storage unit if it is deemed reasonably necessary for a geologic storage project, provided the operations plan in the order is approved by the persons collectively owning at least 75% of the included storage resources.

When does ECMC accept public comments for Class VI applications?

Members of the public have multiple opportunities to comment on Class VI projects. All opportunities for public comment will be posted on the Announcement page. For more information on timing, visit the Permit Application Process page.

Are Class VI facilities subject to Colorado’s Cumulative Impacts rules?

Yes. All operators of a Class VI facility involving one or more injection wells are required to submit a Form 50B (Class VI Cumulative Impacts Data Identification) as part of their permit application. Data from this form will contribute to ECMC’s Cumulative Impacts Data Evaluation Repository (CIDER), which informs future data-based decision making about the impacts of energy and carbon management developments in the state. For more information on Cumulative Impacts, visit the ECMC Cumulative Impacts program page.

Who regulates pipelines?

Different state agencies regulate different industries. In some cases, different agencies regulate different components of the same industry! That's because the regulatory agency needs to have the proper subject matter expertise over the matter. Our team of experts at ECMC coordinates regularly with colleagues across all agencies.

In this case, ECMC does not regulate pipelines. CO2 is typically captured from point sources, such as industrial facilities, or through a process known as Direct Air Capture. Supercritical CO2 is transported to the Class VI injection site via pipelines and/or flowlines. Pipelines transporting CO2 are regulated by the Pipeline and Hazardous Material Safety Administration, and include pipelines described in 49 CFR 195 (https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-D/part-195). Any segments transferring CO2 to a geologic storage facility that are not included in 49 CFR 195 are considered flowlines and are regulated by ECMC. For more information, see the technical report titled “Pipeline Report for the State of Colorado: Considerations for Pipeline Safety and Siting.”