Photo of Rachael Beavers

Rachael counsels clients in a broad range of regulatory and commercial matters, including energy generation and storage project development, mergers and acquisitions, and other transactions, with a focus on renewable energy and power generation projects.

On June 17, the Environmental Protection Agency (EPA) published a proposed rule to approve Texas’s application for primary permitting and enforcement responsibility (primacy) for carbon dioxide (CO2) sequestration wells pursuant to the Safe Drinking Water Act’s (SDWA) Class VI Underground Injection Control (UIC) Program. Upon approval of the rule, the Railroad Commission of Texas (RRC) will have permitting and enforcement authority for the Class VI UIC program (with oversight from the EPA). This development is the culmination of lengthy negotiations between the state of Texas and the EPA, which we have previously discussed in more detail.