### 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.

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### September 3, 2009

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

RE: Technical and Economic Hurdles fo r 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 abil ity to look towards programs believed to

cleanup the environment. The intent ion is not to present a case for CO 2 

### in the

environmental and the benefits and harms im posed thereon but to present an objective

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

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

commonly used and accepted approaches for ev aluating reservoir char acteristics.

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 an alysis on the hurdles, scope, cost, and impact

to the supposed global temperature increase imposed on the earth by CO 2 

### 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 K yoto 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 cap abilities 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 un til this paper was published was an objective

reservoir analysis using petroleum engineer ing equations developed from over 100 years

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

the CO 2 

### reaches reservoir boundari es, 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 a nnually to achieve Kyoto Protocol emission

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

nothing is done. The projected global temperature increase is 0.29o C if CO 2 

### is

geologically sequestered. The cost for the US alone is $6.67 Trillion per degree C.

### Furthermore, the Executive and Legislative Bran ches efforts to deal with global warming

by waving their arms and hoping black box solu tions 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 temperat ure records from sens ors inappropriately

placed and not in conformance with NOAA standards 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 weat her; let alone temperatures 20 years out.

It is therefore suggested to drop all illusions of managing CO 2 

### either using the Clean Air

Act or new legislation using geologic car bon sequestration as th e 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 ot her legal hurdles to

address before carbon capture and sequestra tion 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 CO 2 

### 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 availabl e 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 Read ing Room to view

or receive a copy of this docu ment. 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.govLetter 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 toestimations 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.