This comment letter response contains two parts:

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA

‐ assigned comment code; and an

individual response. These are described and explained below.

• The data base contains Comment text from the letters submitted by commenters.

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues. However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID. Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments. Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter. As a result of this process, there is

repetition in the response text. The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.

Responses on each topic area are compiled and are also available in the rulemaking docket.Letter ID: 0298

Commenter: Kyle Isakower

Organization: American Petroleum Institute

Letter ID: 0298 Comment ID: 29317 Letter Lines: 25 to 81

Comment Code: 1000 1. General and Administrative Comments

Comment: The organizations identified below request that the Environmental Protection

Agency (EPA) extend from November 24, 2008 to December 19,2008 the public

comment period on the proposed rule for ge ologic sequestration of carbon dioxide

under the Safe Drinking Water Act (SDWA) . "Federal Requirements Under the

Underground Injection Cont rol (UIC) Program for Carbon Dioxide (C02) Geologic

Sequestration (GS) Wells", 73 Fe d. Reg. 43491-541 July 25, 2008). The

organizations supporting this request represent a broad array of interests in

the issues associated with this rulemaki ng and many of us have been discussing

these interests and issues in an effort to reach consensus or at least narrow

our differences. We request this extensi on so we can continue efforts toward

submission of recommendations reflecting common views on a number of the major

issues in this rulemaking on which EPA e xpressly requested comment and several

other issues that have arisen dur ing our dialogue on this rulemaking.

Initially facilitated by EPA's technical workshops to devel op understanding and

helpful public meetings to discuss EPA' s rulemaking approach, our discussions

have been enhanced by the efforts of the Ground Water Protection Council, the

Interstate Oil and Gas Compact Commission and the World Resources Institute, in

which many of our organizations have pa rticipated. They ha ve been further

informed by the ongoing research effort s of the Regional Carbon Sequestration

Partnerships under the support of the Depart ment of Energy and a number of other

research activities and meetings conduc ted by academic and other institutions

actively involved in techni cal research and information exchanges on the issues

underlying this rulemaking, in which re presentatives or members of our

organizations have participated. As a result of EPA's proposal, dialogue on

these issues has expanded, become more fo cused and achieved substantial progress

in reaching agreement on a number of issu es that should better inform EPA's

development of its final rule.

We have already agreed that EPA's propos al provides a solid foundation on which

to develop the regulatory framework for geologic sequestration on issues within

the purview of the SDWA and that developm ent of this rule should proceed with

EPA's proposal as the starting point. The issues on which we believe additional

time would be helpful to development of common views or unde rstanding include:

- The establishment of injection pressure limitations for geologic sequestration

injection wells;

1- How various types of target formations should be addressed w ithin the underground

injection control (UIC) progr am, including requirements fo r geologic sequestration

in oil and gas reservoirs;

- The process and criteria for achieving closure of geologic seque stration projects;

- Consideration of current and potential future source waters in areas with constrained

water resources; and

- Addressing issues relating to public wa ter systems in proximity to geologic

sequestration projects.

We believe that the requested limited ex tension of the public comment period

will allow time for continuation of diligen t efforts to reach consolidation of

shared understanding on thes e issues and possibly submi ssion of recommendations

reflecting that understanding and signifi cant agreement on how these issues can

be addressed and resolved. The undersigned submit this request on behalf of the

listed organizations that have author ized submission of their names as

supporters of this request.

Individual Response: Robert F. Van Voorhees

Partner, Environmental Group

Bryan Cave LLP

700 Thirteenth Street, N.W.

Suite 700

Washington, D.C. 20005-3960

Dear Mr. Van Voorhees:

Thank you for your letter of November 17,2008 to Stephen L. Johnson,

Administrator of the U.S. Environmental Protection Agency (EPA), transmitting a

request from multiple organizations seeki ng an extension on EPA's proposed rule for

geologic sequestration under the Safe Dri nking Water Act (SDWA). I have been asked

to respond to your letter.

In response to your request, Assistan t Administrator Benjamin Grumbles

extended the comment period for the notice through December 24,2008. This was

announced in a Federal Register notice on November 21,2008.

We are pleased to see that the signatory organizations to th e letter are working

together to understand each other's perspect ive and work through issues of concern. We

hope that the additional time afforded by the ex tension will result in comments that will

help the Agency develop a rule that will a llow the technology to move forward while also

ensuring protection of underground sources of drinking water.

23 Thank you again for your letter. Please shar e this information with the supporters

of the request. If you have any questions, please contact me or Steve Heare, Director of

the Drinking Water Protec tion Division, at 202-564-3751.

Sincerely,

Cynthia C. Dougherty, Director

Office of Ground Water and Drinking Water