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Responses on each topic area are compiled and are also available in the rulemaking docket.
September 3, 2009 

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

RE: Technical and Economic Hurdles for Carbon Geological Sequestration 

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

Thank you for reopening the comment period for this important issue. Carbon geological 

sequestration is the backbone of the Cap and Trade Legislation approved by the House 

and planned hearing in the Senate. 

When the economy grows there is the ability to look towards programs believed to 

cleanup the environment. The intention is not to present a case for CO2 in the 

environmental and the benefits and harms imposed thereon but to present an objective 

analysis of the sequestration reservoir characteristics based on over 100 years of 

petroleum engineering. The analysis presented in the attached paper is based on 

commonly used and accepted approaches for evaluating reservoir characteristics. 

The Society of Petroleum Engineers paper titled, “The Impact of Carbon Geologic 

Sequestration,” by Xian Vie, University of Wyoming and Michael J. Economides, SPE, 

University of Houston presents a generic analysis on the hurdles, scope, cost, and impact 

to the supposed global temperature increase imposed on the earth by CO2 emissions. 

Based on this analysis a large number of carbon sequestration wells on the order of 7,000 

to 66,500 were needed in 2008 to achieve the Kyoto Protocol emissions reductions. This 

number escalates to 16,700 to 161,500 by 2030. The ability to drill, complete and service 

these wells would highly likely stretch the US productive drilling capabilities directing 

the resources from production to sequestration. Other critical technological hurdles yet to 

be addressed are discussed below. 

Another critical analysis I have not found until this paper was published was an objective 

reservoir analysis using petroleum engineering equations developed from over 100 years 

of collective experience. The analysis demonstrates that injectivity decays over time as 

the CO2 reaches reservoir boundaries, more commonly understood as compaction. As a 

result, additional wells are needed to continue sequestration of the steady state emissions 

from the power plant. 

The estimated cost is nearly $1 Trillion annually to achieve Kyoto Protocol emission 

reductions. The projected global temperature increase is 0.44o C from 2008 to 2030 if 

nothing is done. The projected global temperature increase is 0.29o C if CO2 is 

geologically sequestered. The cost for the US alone is $6.67 Trillion per degree C. 
Furthermore, the Executive and Legislative Branches efforts to deal with global warming 

by waving their arms and hoping black box solutions become available could, and will 

highly likely do more damage discouraging young Americans from selecting a career in 

the sciences and Engineering since they will soon become disillusioned with science and 

engineering’s inability to solve this problem. Ex nihilo, or creating something from 

nothing, as this administration and its legislative allies are doing could do irreparable 

harm to America’s creative abilities to solve tough technical problems. 

This postulated problem is based on temperature records from sensors inappropriately 

placed and not in conformance with NOAA standards2, misrepresentation of basis 

equilibrium chemistry as far as the ice record is concerned, and models and results when 

it is difficult to predict tomorrow’s weather; let alone temperatures 20 years out. 

It is therefore suggested to drop all illusions of managing CO2 either using the Clean Air 

Act or new legislation using geologic carbon sequestration as the featured technology 

until it can be proven that global warming is indeed an apocalyptic event and/or other 

more reasonable technologies become available. Indeed, there are other legal hurdles to 

address before carbon capture and sequestration can even be considered a viable 

alternative. As an example, exceeding the fracture gradient would more than likely cause 

a vertical fracture that could cause a catastrophic release of CO2 to the environment. 

Sincerely, 

Jeffrey A. Miller, P.E., BCEE 

References 

1) The Impact of Carbon Geologic Sequestration, Xina Xie, SPE, University of 

Wyoming, and Michael J. Economides, SPE, University of Houston, SPE 120333, 

presented at the 2009 SPE American E&P Environmental Health and Safety 

Conference, San Antonio, Texas, March 2009. 

2) Is the US Surface Temperature Record Reliable?, By Anthony Watts, The 

Heartland Institute, 2009. 

3) Nature, Not Human Activity, Rules the Climate, Science and Environmental 

Policy Project April 2008, Published by THE HEARTLAND INSTITUTE. 
This document is not available in Regulations.gov since it 

contains copyrighted material that may not be reproduced 

without consent of the copyright holder. 

Contact the EPA Docket Center, Public Reading Room to view 

or receive a copy of this document. Requests for copies may be 

made as follows: 

In person/writing: 

Environmental Protection Agency, Docket Center 

1301 Constitution Ave NW, 2822T, Room 3334 

Washington, DC. 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
Letter ID: 0331  

Commenter: Jeffrey A. Miller  

   

Letter ID: 0331 Comment ID: 27931 Letter Lines: 28 to 55  

Comment Code: 2400 2.4. Other Research Offered by Commenters (seeking comment)  

Comment: When the economy grows there is the ability to look towards programs believed to  

cleanup the environment. The intention is not to present a case for CO2 in the  

environmental and the benefits and harms imposed thereon but to present an  

objective analysis of the sequestration reservoir characteristics based on over  

100 years of petroleum engineering. The analysis presented in the attached  

paper is based on commonly used and accepted approaches for evaluating reservoir  

characteristics.  

The Society of Petroleum Engineers paper titled, "The Impact of Carbon Geologic  

Sequestration," by Xian Vie, University of Wyoming and Michael J. Economides,  

SPE, University of Houston presents a generic analysis on the hurdles, scope,  

cost, and impact to the supposed global temperature increase imposed on the  

earth by CO2 emissions. [SEE EPA‐HQ‐OW‐2008‐0390‐0331.PDF FOR ARTICLE]  

Based on this analysis a large number of carbon sequestration wells on the order  

of 7,000 to 66,500 were needed in 2008 to achieve the Kyoto Protocol emissions  

reductions. This number escalates to 16,700 to 161,500 by 2030. The ability to  

drill, complete and service these wells would highly likely stretch the US  

productive drilling capabilities directing the resources from production to  

sequestration. Other critical technological hurdles yet to be addressed are  

discussed below.  

Another critical analysis I have not found until this paper was published was an  

objective reservoir analysis using petroleum engineering equations developed  

from over 100 years of collective experience. The analysis demonstrates that  

injectivity decays over time as the CO2 reaches reservoir boundaries, more  

commonly understood as compaction. As a result, additional wells are needed to  

continue sequestration of the steady state emissions from the power plant.  

Individual Response: EPA has reviewed the paper entitled “The Impact of Carbon Geologic

Sequestration.” EPA acknowledges the submittal and will continue to review studies related to
estimations of the number of GS wells that may be drilled and used, limitations to injectivity, and the

subsequent need for additional drilling as it makes changes to adapt in light of new data and research.  

Letter ID: 0331 Comment ID: 27932 Letter Lines: 57 to 84  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: The estimated cost is nearly $1 Trillion annually to achieve Kyoto Protocol  

emission reductions. The projected global temperature increase is 0.44o C from  

2008 to 2030 if nothing is done. The projected global temperature increase is  

0.29o C if CO2 is geologically sequestered. The cost for the US alone is $6.67  

Trillion per degree C. Furthermore, the Executive and Legislative Branches  

efforts to deal with global warming by waving their arms and hoping black box  

solutions become available could, and will highly likely do more damage  

discouraging young Americans from selecting a career in the sciences and  

Engineering since they will soon become disillusioned with science and  

engineering’s inability to solve this problem. Ex nihilo, or creating something  

from nothing, as this administration and its legislative allies are doing could  

do irreparable harm to America’s creative abilities to solve tough technical  

problems.  

This postulated problem is based on temperature records from sensors  

inappropriately placed and not in conformance with NOAA standards [FOOTNOTE 2],  

misrepresentation of basis equilibrium chemistry as far as the ice record is  

concerned, and models and results when it is difficult to predict tomorrow’s  

weather; let alone temperatures 20 years out.  

It is therefore suggested to drop all illusions of managing CO2 either using the  

Clean Air Act or new legislation using geologic carbon sequestration as the  

featured technology until it can be proven that global warming is indeed an  

apocalyptic event and/or other more reasonable technologies become available.  

Indeed, there are other legal hurdles to address before carbon capture and  

sequestration can even be considered a viable alternative. As an example,  

exceeding the fracture gradient would more than likely cause a vertical fracture  

that could cause a catastrophic release of CO2 to the environment.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.