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.
~ 

Ameren 

Ameren Services 

Enl';ronmtntal SeO';ces 

314554.2388 (Phone) 

314554.4182 (Facsimile) 

ppike@dmeren.com 

October 14, 2009 

U.S. Environmental Protection Agency 

Water Docket 

Mail Code 4101T 

1200.Pennsylvania Ave., NW 

Washington, D.C. 20460 

Submitted on-line: www.regulations.gov 

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

One Ameren Plaza 

1901 Chouteau Avenue 

PO Box 66149 

St. Louis, MO 63166-6149 

Re: Comments on Notice of Data Availability for Federal Requirements 

Under the Underground Injection Control role) Program for Carbon 

Dioxide (C02) Geologic Sequestration (GS) Wells. 74 Fed. Reg. 44802 

(Aug. 31. 2009) 

To whom it may concern: 

Ameren Corporation appreciates the opportunity to comment on the Notice of Data 

Availability and Request for Comment ("NODA") relating to the proposed Federal 

Requirements Under the Underground Injection Control ("VIC") Program for 

Carbon Dioxide ("C02") Geologic Sequestration ("GS") Wells. 74 Fed. Reg. 

44802 (Aug. 31, 2009). We submitted comments last December on EPA's 

proposal to regulate C02 GS under the UIC program. See 73 Fed. Reg. 43492 

(July 25, 2008). 

Ameren Corporation ("Ameren") is based in SI. Louis, MO, and through its 

operating companies serves 2.4 million electric and nearly one million natural gas 

customers across a 64,OOO-square-mile area in Illinois and Missouri. Ameren 

companies' net generating capacity is more than 16,400 megawatts. Our power 

plants use a variety of fuels to generate electricity-prineipally coal, nuclear, hydro 

and natural gas. In 2007, coal-fired generation accounted for 84 percent of our 

total electric generation; 12 percent came from the company's single-unit nuclear 

plant; 2 percent from natural gas-fired units; and 2 percent from hydroelectric 

plants. 

The Ameren family of companies operates through multiple subsidiaries in 

different regulatory environments. In Missouri, Ameren's utility subsidiary, 

AmerenUE, generates electricity, delivers natural gas and electricity and is 

8 subsidiary of Amsren Corporation 
regulated by a state-appointed commission. Ameren is the parent company to three 

Illinois utilities (collectively referred to as the Ameren Illinois Utilities) which 

deliver natural gas and electricity and are regulated by a state-appointed 

commission. Ameren also owns a number of non-rate-regulated subsidiaries, 

including AmerenEnergy Resources, which is the holding company for some of 

Ameren's non-rate-regulated power marketing and generating companies. 

Regulation of GS under the UIC program will have a direct impact on Ameren, 

particularly our fossil-fired facilities involved in the production of electricity and 

we have a substantial interest in EPA's development of a realistic and costeffective UIC program for Class VI CO2 GS wells. Ameren is a member of the 

Utility Solid Waste Activities Group ("USWAG"), the Edison Electric Institute 

("EEl"), and the Electric Power Research Institute ("EPRI)". We endorse the 

comments filed by USWAG, EEl, and EPRI. 

At the outset, Ameren applauds EPA's careful approach to the development of C02 

GS regulations, including this most recent release of additional data. Because the 

technology contemplated in the C02 GS proposal will not be commercially 

deployed for many years, it is essential the Final Rule be flexible enough to 

accommoclate clevelopments in information and technology related to carbon 

sequestration. It is critical that EPA develop a regulatory regime incorporating 

performance-based standards in order to allow for site-tailored requirements that 

will reflect the vast differences among various potential CO2 GS sites. 

We support EPA's suggestion to adopt a flexible waiver process to allow for C02 

GS injection above and between underground sources of drinking water 

("USDWs"). 74 Fed. Reg. at 44810. As stated in the NODA, EPA's original 

proposal to define Class VI injection wells as those used for injection of CO2 

beneath the lowermost formation containing a USDW (73 Fed. Reg. at 43511) 

would preclude injection of C02 into zones between and above USDWs, thereby 

restricting or rendering impossible CO2 GS sites in large areas of the country with 

deep USDWs. 74 Fed. Reg. at 44808. The proposal would also prohibit CO2 

injection into many shallow formations such as coal seams and basalts. 73 Fed. 

Reg. at 43512. As the NODA observes, a number of states have indicated that 

regions with very deep and layered USDWs could not undertake C02 GS projects 

because injectors could not comply with the proposed injection depth and well 

construction requirements. 74 Fed. Reg. at 44809. 

EPA addresses these concerns by the proposal set forth in the NODA to keep the 

originall y proposed injection depth requirement but allow owners or operators to 

apply for a site-specific waiver from those injection depth requirements upon 

making a demonstration that such injection can be undertaken in a manner that 

prevents the endangerment of public health from USDW contamination. Id. at 

44810. Ameren believes that such a flexible approach would ensure adequate 

protection of USDWs while recognizing the vast geographic and topographic 

differences between potential C02 GS sites throughout the country, allowing for 

maximization of safe C02 storage capacity nationwide. 
While Arneren supports the flexible injection depth waiver proposal described 

above, we urge EPA to consider requiring the inclusion of such a waiver provision, 

rather than leaving the adoption of an injection depth waiver process to the 

discretion of the individual UIC Program Directors. Id. at 44811. While it is true 

that deep USDWs do not exist in every state and that states without USDWs may 

choose not to grant waivers, inclusion of a waiver provision would still leave UIC 

Program Directors free to decline to grant any waivers where not necessary or 

appropriate. See id. C02 GS technology is rapidly developing; because this 

experience with and information regarding this technology is growing rapidly, it is 

prudent to structure a regulatory framework that is flexible enough to respond to 

developments in the field. 

Ultimately, In drafting a final rule, EPA should strive to develop clear guidelines 

for decision makers in evaluating waiver applications as well as the development 

of a transparent and, to the extent possible, outcome-predictable process to provide 

guidance for future applicants. In terms of the substantive requirements for waiver 

applicants, the Agency should guard against the insertion of unnecessary 

complexity and redundancy into the process that bring no corresponding increase 

in protection of USDWs. 

Finally, as EPA acknowledges in the NODA, the Department of Energy ("DOE") 

is developing and/or operating a number of C02 GS pilot projects throughout the 

country. These pilot projects share a common purpose: in EPA's own words, to 

"help determine the best approaches for capturing and permanently storing" gases 

such as C02, as well as to determine "the most suitable technologies, regulations, 

and infrastructure needs for carbon capture, storage, and sequestration in different 

parts of the country." 74 Fed. Reg. at 44805. 

The NODA discusses three experimental GS projects as well as research being 

conducted regarding the potential effects on USDWs in the highly unlikely event 

that injected C02 migrates from the receiving formation. In evaluating the 

techniques employed in these projects and the data produced, the Agency should 

keep in mind that experimental projects are just that-experimental projects. The 

techniques employed in any given setting may have much to offer the project, but 

their successful employment in such a setting should not necessarily dictate their 

universal application. 

Arneren appreciates EPA's effort to broaden their base.of knowledge by drawing 

on the experiences of these pilot projects prior to issuing a final rule. We are 

concerned, however, that this NODA may be premature, as it reflects data from 

only a handful of the approximately thirty pilot projects affiliated with DOE. For 

example, the Plains C02 Reduction Partnership ("PCOR") has only recently 

completed and submitted information regarding their Phase II findings; these data, 

as well as similar data from other pilot projects, are not reflected in the NODA. 

This information will provide valuable insight into the advantages, limitations, and 

challenges associated with C02 GS in different parts of the country. Arneren 

urges EPA to consider the results of all DOE pilot projects prior to drafting a final 
C02 GS rule, and to make this information available for public review and 

comment in a subsequent NODA prior to promulgation of a final rule. 

The NODA notes that many commenters on the proposed rule encouraged the 

Agency to consider a more "comprehensive framework" for GS, addressing issues 

arising under statutes other than SDWA, such as the Clean Air Act, the Resource 

Conservation and Recovery Act, and the Comprehensive Environmental Response, 

Compensation and Liability Act. It further states that the Agency "is currently 

evaluating the need for a more comprehensive regulatory framework," and that if 

the Agency "chooses to pursue" such a framework, it will seek public comment on 

any proposal it develops. 74 Fed. Reg. at 44805 

At the same time, while separate regulations for CCS are to some extent necessary, 

Ameren encourages the Agency to avoid piecemeal regulation to the extent 

possible and develop a single rule to address issues arising outside the SDW A 

context. In the last year, the Agency has considered various provisions directly 

impacting CCS projects under the Agency's proposed rule on Mandatory 

Reporting of Greenhouse Gases (Docket ID No. EPA-HQ-ORA-2008-0508), 74 

Fed. Reg. 16448 (April 10, 2009), as well as its proposed changes to the 

Renewable Fuel Standard (RFS) Program (Docket ID No. EPA-HQ-OAR-2oo5-

0161),74 Fed. Reg. 24904 (May 26, 2009), raising concerns that CCS may be 

unnecessarily governed through a patchwork of separate provisions. A holistic 

approach to CCS to the greatest extent possible is of critical importance to ensuring 

efficient development and commercial deployment of CCS technologies. 

Ameren appreciates the opportunity to comment on this new data and EPA's new 

proposal for an injection depth waiver process and would welcome the opportunity 

to work further with the Agency. Please feel free to contact me at 314-554-2388 or 

prpike@ameren.com with any questions. 

Paul R. Pike 

Strategic Analyst-Environmental Services 
Letter ID: 0354  

Commenter: Paul R. Pike  

Organization: Ameren Corporation  

Letter ID: 0354 Comment ID: 28071 Letter Lines: 68 to 75  

Comment Code: 1000 1. General Comments on the Notice of Data Availability  

Comment: At the outset, Ameren applauds EPA's careful approach to the development of CO2  

as regulations, including this most recent release of additional data. Because  

the technology contemplated in the CO2 GS proposal will not be commercially  

deployed for many years, it is essential the Final Rule be flexible enough to  

accommodate developments in information and technology related to carbon  

sequestration. It is critical that EPA develop a regulatory regime incorporating  

performance‐based standards in order to allow for site‐tailored requirements  

that will reflect the vast differences among various potential CO2 as sites.  

Individual Response: EPA believes that the final rule is based on the most recent GS‐related data,

information, and scientific research available. EPA intends to continue to collect data on GS and to

incorporate such data as it implements its adaptive approach to GS rulemaking to incorporate new

research, data, and information about GS. The Agency believes that an adaptive approach provides Class

VI owners or operators the flexibility to use and apply newly developed technologies for GS as they

become available in the future.  

EPA agrees with the commenter that a site‐specific approach to permitting GS sites is important. The

final rule provides Class VI owners or operators the flexibility to select technologies appropriate for a

specific site and affords the Director flexibility to establish permit requirements on the basis of site‐

specific characteristics. For additional information on the adaptive approach and site‐specific

requirements, see the responses to comments on the proposed rule in the rulemaking docket.  

Letter ID: 0354 Comment ID: 28072 Letter Lines: 77 to 99  

Comment Code: 3210 3.2.1. Comments Generally in Support of the Approach  

Comment: We support EPA's suggestion to adopt a flexible waiver process to allow for C02  

as injection above and between underground sources of drinking water ("USDWs").  

74 Fed. Reg. at 44810. As stated in the NODA, EPA's original proposal to define  

Class VI injection wells as those used for injection of CO2 beneath the  
lowermost formation containing a USDW (73 Fed. Reg. at 43511) would preclude  

injection of CO2 into zones between and above USDWs, thereby restricting or  

rendering impossible C02 as sites in large areas of the country with deep USDWs.  

74 Fed. Reg. at 44808. The proposal would also prohibit CO2 injection into many  

shallow formations such as coal seams and basalts. 73 Fed. Reg. at 43512. As the  

NODA observes, a number of states have indicated that regions with very deep and  

layered USDWs could not undertake CO2as projects because injectors could not  

comply with the proposed injection depth and well construction requirements. 74  

Fed. Reg. at 44809.  

EPA addresses these concerns by the proposal set forth in the NODA to keep the  

originally proposed injection depth requirement but allow owners or operators to  

apply for a site‐specific waiver from those injection depth requirements upon  

making a demonstration that such injection can be undertaken in a manner that  

prevents the endangerment of public health from USDW contamination. Id. at  

44810. Ameren believes that such a flexible approach would ensure adequate  

protection of USDWs while recognizing the vast geographic and topographic  

differences between potential C02 as sites throughout the country, allowing for  

maximization of safe CO2 storage capacity nationwide.  

Individual Response: EPA acknowledges the commenter's support of the waiver approach and site‐

specific flexibility in regulatory development and permitting as described in the NODA and Request for

Comment. The Agency acknowledges that there are some situations where injection into non‐USDW

formations above the lowermost USDW can be performed in a manner that protects USDWs. The final

GS rule at §146.95 establishes a process by which owners and operators can seek a waiver of the Class

VI injection depth requirements. The Agency believes the waiver approach: 1) responds to concerns

about local and regional geologic storage capacity limitations imposed by the proposed injection depth

requirements; 2) allows for a more site‐specific assessment of injection depth for GS projects; 3)

accommodates injection into different formation types; 4) allows for injection of CO2 for GS into non‐

USDWs above and/or between USDWs when appropriate and where it can be demonstrated that

USDWs will be protected; and 5) responds to concerns about the use of aquifer exemptions for GS.

Finally, EPA's approach to addressing injection depth variability through a waiver process responds to

concerns about future drinking water resource availability and the need to ensure that high quality

water remains available in sufficient quantities to supply drinking water needs.  

Letter ID: 0354 Comment ID: 28073 Letter Lines: 101 to 111  

Comment Code: 3390 3.3.9. Comments Regarding State Discretion to Adopt the Waiver Approach  

Comment: While Ameren supports the flexible injection depth waiver proposal described  
above, we urge EPA to consider requiring the inclusion of such a waiver  

provision, rather than leaving the adoption of an injection depth waiver process  

to the discretion of the individual UIC Program Directors. Id. at 44811. While  

it is true that deep USDWs do not exist in every state and that states without  

USDWs may choose not to grant waivers, inclusion of a waiver provision would  

still leave UIC Program Directors free to decline to grant any waivers where not  

necessary or appropriate. See id. CO2 GS technology is rapidly developing;  

because this experience with and information regarding this technology is  

growing rapidly, it is prudent to structure a regulatory framework that is  

flexible enough to respond to developments in the field.  

Individual Response: EPA clarifies that adoption of the waiver process remains at the discretion of

individual UIC programs. Therefore, States, Territories, and Tribes seeking primacy for Class VI wells are

not required to provide for injection depth waivers in their UIC regulations and may choose not to make

this process available to Class VI wells under their jurisdiction. Although some commenters asked EPA to

require that waivers be applied nationally, the Agency believes that the decision about whether a waiver

program is appropriate in a specific State, Tribe, or Territory should be made by each program. This

approach allows flexibility for individual program Directors to determine the appropriateness of allowing

for waivers based on regional or state‐specific conditions, such as the predominant geologic settings

anticipated to be used for GS or other land uses in the state while ensuring maximum protection of

USDWs. The final approach for injection depth waivers represents minimum Federal requirements. UIC

program Directors may adopt GS requirements that do not allow injection above or between USDWs if

they determine this to be appropriate (for conditions in their State, Territory, Tribe, or Region) and

protective.

EPA recognizes that GS technologies are rapidly developing. For this reason, the Agency is adopting an

adaptive rulemaking approach. EPA plans, every six years, to collect and review data on GS projects,

including information on any Class VI wells granted a waiver of the injection depth requirements, 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.  

Letter ID: 0354 Comment ID: 28074 Letter Lines: 113 to 119  

Comment Code: 3240 3.2.4. Comments that the Approach Requests Too Much Data (seeking comment)  

Comment: Ultimately, in drafting a final rule, EPA should strive to develop clear  

guidelines for decision makers in evaluating waiver applications as well as the  

development of a transparent and, to the extent possible, outcome‐predictable  

process to provide guidance for future applicants. In terms of the substantive  

requirements for waiver applicants, the Agency should guard against the  
insertion of unnecessary complexity and redundancy into the process that bring  

no corresponding increase in protection of USDWs.  

Individual Response: EPA believes that the information required to obtain a waiver is necessary to

ensure that the owner or operator collects information and demonstrates to the Director that the

injection zone is suitable for GS, is confined by confining units above and below the injection zone, and

that well construction, operation, and monitoring are tailored for the site and take into consideration

the presence of USDWs above and below the injection zone. Because USDW protection is the priority of

the GS rule, owners or operators seeking waivers must provide a supplemental report (the GS Class VI

injection depth waiver application report), referenced at §146.82(d) and outlined at §146.95(a), with

their Class VI permit applications. This report, suggested by commenters, is designed to ensure that all

waiver information is discrete (from the permit application) and can be made available to the Director,

PWSS Directors, and the public when the waiver is publicly noticed with the draft Class VI permit

application. The Agency believes that this report and requirements at §146.95 are complementary and

not redundant of the Class VI permit application requirements. Furthermore, to eliminate concerns

about duplication or redundancy, the requirements at §146.82(d) clarify that the supplemental report is

not part of the permit application.  

The final GS rule also contains a clear and transparent review process. Section 146.95(b) establishes

considerations that the UIC Director must assess when evaluating a waiver application to ensure that

USDW protection, site‐specific drinking water resource issues, and the use and impact of GS

technologies are considered and documented. Section 146.95(c) requires the Director to give public

notice, as part of the permit application process, including notice that a waiver application has been

submitted. If the permitting authority receives comments on the injection depth waiver during the

public comment period for both the waiver and the permit application, the Director in consultation with

the Regional Administrator, must evaluate comments prior to providing a recommendation to the

Regional Administrator regarding a waiver and issuing the Class VI permit.

EPA is developing guidance on the injection depth waiver process. The guidance describes the

recommended approach an owner or operator may follow when submitting a waiver application,

processing waiver applications by the UIC and PWSS Program Directors, and additional considerations

that may apply to projects that have been issued waivers. This guidance will be available on EPA’s

website at water.epa.gov/type/groundwater/uic/wells_sequestration.cfm.  

Letter ID: 0354 Comment ID: 28075 Letter Lines: 121 to 150  

Comment Code: 2100 2.1 DOE Regional Carbon Sequestration Partnership Projects  

Comment: Finally, as EPA acknowledges in the NODA, the Department of Energy ("DOE") is  

developing and/or operating a number of CO2 GS pilot projects throughout the  
country. These pilot projects share a common purpose: in EPA's own words, to  

"help determine the best approaches for capturing and permanently storing" gases  

such as CO2, as well as to determine "the most suitable technologies,  

regulations, and infrastructure needs for carbon capture, storage, and  

sequestration in different parts of the country." 74 Fed. Reg. at 44805.  

The NODA discusses three experimental GS projects as well as research being  

conducted regarding the potential effects on USDWs in the highly unlikely event  

that injected C02 migrates from the receiving formation. In evaluating the  

techniques employed in these projects and the data produced, the Agency should  

keep in mind that experimental projects are just that‐experimental projects. The  

techniques employed in any given setting may have much to offer the project, but  

their successful employment in such a setting should not necessarily dictate  

their universal application.  

Ameren appreciates EPA's effort to broaden their base of knowledge by drawing on  

the experiences of these pilot projects prior to issuing a final rule. We are  

concerned, however, that this NODA may be premature, as it reflects data from  

only a handful of the approximately thirty pilot projects affiliated with DOE.  

For example, the Plains CO2 Reduction Partnership ("PCOR")") has only recently  

completed and submitted information regarding their Phase II findings; these  

data, as well as similar data from other pilot projects, are not reflected in  

the NODA. This information will provide valuable insight into the advantages,  

limitations, and challenges associated with C02 OS in different parts of the  

country. Ameren urges EPA to consider the results of all DOE pilot projects  

prior to drafting a final C02 GS rule, and to make this information available  

for public review and comment in a subsequent NODA prior to promulgation of a  

final rule.  

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 useful 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.  
Letter ID: 0354 Comment ID: 28076 Letter Lines: 152 to 172  

Comment Code: 1100 1.1 Comments on the Comprehensive Approach  

Comment: The NODA notes that many commenters on the proposed rule encouraged the Agency  

to consider a more "comprehensive framework" for GS, addressing issues arising  

under statutes other than SDWA, such as the Clean Air Act, the Resource  

Conservation and Recovery Act, and the Comprehensive Environmental Response,  

Compensation and Liability Act. It further states that the Agency "is currently  

evaluating the need for a more comprehensive regulatory framework," and that if  

the Agency "chooses to pursue" such a framework, it will seek public comment on  

any proposal it develops. 74 Fed. Reg. at 44805  

At the same time, while separate regulations for CCS are to some extent  

necessary, Ameren encourages the Agency to avoid piecemeal regulation to the  

extent possible and develop a single rule to address issues arising outside the  

SDWA context. In the last year, the Agency has considered various provisions  

directly impacting CCS projects under the Agency's proposed rule on Mandatory  

Reporting of Greenhouse Gases (Docket ID No. EPA‐HQ‐ORA‐2008‐0508), 74 Fed. Reg.  

16448 (April 10, 2009), as well as its proposed changes to the Renewable Fuel  

Standard (RFS) Program (Docket ID No. EPA‐HQ‐OAR‐20050161), 74 Fed. Reg. 24904  

(May 26, 2009), raising concerns that CCS may be unnecessarily governed through  

a patchwork of separate provisions. A holistic approach to CCS to the greatest  

extent possible is of critical importance to ensuring efficient development and  

commercial deployment of CCS technologies.  

Individual Response: EPA acknowledges that GS falls within the broader context of CCS and the need for

regulatory clarity to ensure that USDWs are protected from endangerment. In developing the final GS

rule, the Office of Water coordinated with other Agency program offices and across federal agencies

(e.g., with the Department of Energy; United States Geological Survey; Bureau of Ocean Energy

Management, Regulation, and Enforcement, formerly the Minerals Management Service; Bureau of

Land Management). The Agency continues to evaluate areas of potential applicability of other Federal

environmental statutes including, but not limited to: the Clean Air Act; the Resource Conservation and

Recovery Act; the Comprehensive Environmental Response, Compensation, and Liability Act; and the

Marine Protection, Research and Sanctuaries Act to various aspects of GS and CCS. The Agency will

continue to coordinate on GS and CCS related issues to minimize redundancy and maximize efficiencies

for owners or operators. For additional information, please see the discussion entitled "How Does This

Rulemaking Relate to Other Federal Authorities and GS and CCS Activities?" in the preamble to the final

GS rule.