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.
COMMENTS ON THE U.S. ENVIRONMENTAL PROTECTION AGENCY’S 

PROPOSED RULE FOR FEDERAL REQUIREMENTS UNDER THE 

UNDERGROUND INJECTION CONTROL (UIC) PROGRAM FOR CARBON 

DIOXIDE (CO2) GEOLOGIC SEQUESTRATION (GS) WELLS – NOTICE OF 

DATA AVAILABILITY (NODA) 

Docket ID No. EPA-HQ-OW-2008-0390

Introduction 

The Energy & Environmental Research Center (EERC) at the University of North Dakota

directs the Plains CO2 Reduction (PCOR) Partnership, one of seven regional partnerships 

funded by the U.S. Department of Energy’s Regional Carbon Sequestration Partnership 

(RCSP) Program and a broad range of project sponsors. The PCOR Partnership is a 

diverse group of public and private sector stakeholders working together to better 

understand the technical and economic feasibility of capturing and storing CO2 emissions 

from stationary sources of CO2 in the central interior of North America. 

General Comment

The U.S. Environmental Protection Agency (EPA) should be applauded for its efforts in 

“actively tracking the progress” of the RCSP’s projects. As the RCSPs are currently in 

the process of finalizing the results of their Phase II efforts, it is imperative that EPA take 

into account the substantial body of research soon to be released when finalizing its 

currently proposed rules. The availability of such data will contribute greatly to EPA’s 

understanding of site characterization, well construction, site operation, and monitoring 

requirements. That being said, EPA should use caution when using the various 

construction, operation, and monitoring techniques utilized throughout the duration of 

these tests as validation for the Class VI requirements as proposed. The very purpose of 

the RCSP Phase II efforts was to examine multiple well construction and development 

techniques as well as numerous monitoring, verification, and accounting technologies to 

find the most effective methods for a given site, not to imply that all methodologies 

applied at all research sites are required for the safe and effective geologic storage of 

CO2. 

There are additional comments that could be made with regard to the current NODA; 

however, if EPA practices due diligence in reviewing the RCSP data that will soon be 

publicly available, those issues will address themselves. 

Whether EPA extends the deadline of this NODA or decides to issue another NODA, it is 

the belief of the PCOR Partnership that it would be irresponsible to move forward with 

rule promulgation without first reviewing the vast amount of data that encompass the 

breadth of knowledge gained as a result of the RCSP research. 
Letter ID: 0352  

Commenter: Edward Steadman  

Organization: Energy & Environmental Research Center (EERC)  

Letter ID: 0352 Comment ID: 28057 Letter Lines: 34 to 57  

Comment Code: 2100 2.1 DOE Regional Carbon Sequestration Partnership Projects  

Comment: The U.S. Environmental Protection Agency (EPA) should be applauded for its  

efforts in "actively tracking the progress" of the RCSP's projects. As the RCSPs  

are currently in the process of finalizing the results of their Phase II  

efforts, it is imperative that EPA take into account the substantial body of  

research soon to be released when finalizing its currently proposed rules. The  

availability of such data will contribute greatly to EPA's understanding of site  

characterization, well construction, site operation, and monitoring  

requirements. That being said, EPA should use caution when using the various  

construction, operation, and monitoring techniques utilized throughout the  

duration of these tests as validation for the Class VI requirements as proposed.  

The very purpose of the RCSP Phase II efforts was to examine multiple well  

construction and development techniques as well as numerous monitoring,  

verification, and accounting technologies to find the most effective methods for  

a given site, not to imply that all methodologies applied at all research sites  

are required for the safe and effective geologic storage of CO2 .  

There are additional comments that could be made with regard to the current  

NODA; however, if EPA practices due diligence in reviewing the RCSP data that  

will soon be publicly available, those issues will address themselves.  

Whether EPA extends the deadline of this NODA or decides to issue another NODA,  

it is the belief of the PCOR Partnership that it would be irresponsible to move  

forward with rule promulgation without first reviewing the vast amount of data  

that encompass the breadth of knowledge gained as a result of the RCSP research.  

Individual Response: EPA believes that the regional partnerships provide important information on GS,

but recognizes that use of a technology in a RCSP project does not make a technology valid for all

applications. Each project will be unique and the final rule provides for site‐specific approaches to

ensure that appropriate construction, operation, and monitoring is performed at each site. However, by

testing multiple technologies, the pilot sites provide valuable data that demonstrate whether or not

these technologies are viable and informed the final GS rule.
EPA intends to continue monitoring these projects for information, but EPA also believes it is necessary

not to delay the regulations as a common nationwide approach is needed to oversee this growing

activity.  

EPA intends to use an adaptive approach to the GS regulation. EPA plans, every six years, to collect and

review data on GS projects to determine whether the appropriate amount and types of information and

appropriate documentation are being collected, and to determine if modifications to the requirements

are appropriate or necessary.