Challenge

As carbon capture and storage (CCS) investment accelerated across the Southwest, New Mexico sought authority from the U.S. Environmental Protection Agency (EPA) to administer its own Class VI Underground Injection Control (UIC) program for geologic carbon sequestration. Achieving Class VI primacy required the State to develop a technically rigorous, legally defensible, and federally compliant regulatory framework that demonstrates equal or greater protection of underground sources of drinking water while addressing New Mexico’s unique geology, energy resources, and stakeholder needs.

Solutions

As a key member of the State’s primacy team, GLA provided integrated engineering, technical, legal, and regulatory expertise under the leadership of the New Mexico Oil Conservation Division (OCD), working alongside New Mexico Institute of Mining and Technology, state agencies, and project partners. Our specialists helped develop the technical program framework, regulatory crosswalks, draft rules, and supporting application materials required to demonstrate compliance with EPA Class VI standards. By combining deep subsurface engineering knowledge, regulatory strategy, and practical implementation experience, we helped position New Mexico to build a science-based, efficient, and protective carbon storage program.

Results

GLA’s contributions supported New Mexico’s advancement toward Class VI primacy, a significant milestone that can streamline permitting timelines, strengthen state oversight of carbon sequestration projects, and enhance the State’s ability to attract investment in CCS infrastructure. The effort lays the foundation for long-term carbon management solutions while maintaining rigorous environmental safeguards and regulatory accountability.

Securing Class VI primacy demands more than regulatory compliance. It requires a deep understanding of geology, engineering, risk management, and stakeholder priorities. By bringing those disciplines together, our team helped create a framework that supports both environmental protection and responsible economic growth. We help clients solve complex technical challenges with confidence and credibility.” – Dr. Gregory Schnaar, Project Manager