Challenge

The New Mexico Energy, Minerals and Natural Resources Department was in the process of applying for regulatory primacy under the EPA Class VI program in order to oversee carbon caputure and storage (CCS) projects. This required drafting of a technical and regulatory framework to align with EPA’s Class VI requirements.

Solutions

New Mexico Tech contracted DBS&A as the primary technical author of New Mexico’s Class VI UIC regulations to support the state’s application to oversee CCS projects. DBS&A began drafting state-specific Class VI regulations that align with EPA requirements while also addressing New Mexico’s geologic, hydrogeologic, and policy context. Our team also prepared supporting documentation to demonstrate program equivalency, include rule crosswalks and implementation strategies.

Our team has also worked closely with state agency staff and stakeholders to develop these policies and assist with permitting requirements. Our team has provided technical guidance to state agency staff on permitting workflows, AoR evaluation, plume and pressure front tracking, financial assurance, and long-term site care. Our team also contributed to stakeholder outreach efforts, including technical presentations on Class VI monitoring approaches and regulatory considerations, to support transparent and informed rulemaking. We reviewed and integrated feedback from these stakeholders, as well as from legal counsel and regulators, to refine the rule package.

Results

The finalized regulations produced by DBS&A are durable and science-based, providing the state with policies that meet all necessary EPA requirements while also meeting the specific needs of New Mexico’s geologic landscape. Our work in providing technical guidance to state agency staff has not only helped to provide an efficient implementation of the guidelines but also assistance with long-term site care.

This work reflects DBS&A’s deep expertise in Class VI permitting and policy development, and its commitment to supporting states in building durable, science-based regulatory programs for CCS.