IEEFA comments to EPA on emergency and remedial measures for Brown Pelican Project

The Institute for Energy Economics and Financial Analysis (IEEFA) has submitted comments to the Environmental Protection Agency (EPA) about the draft permits issued to Oxy Low Carbon Ventures LLC’s (OLCV) for three Class VI wells at the Brown Pelican Project, Texas. The comments focus on the inadequate emergency and remediation measures and insufficient financial assurances included in the draft permits that would allow the injection of 8.5 million metric tons of carbon dioxide over 12 years.

The draft permits issued to OLCV do not adequately prioritize the safety of underground drinking water or provide sufficient details for remediation actions in the event of contamination. OLCV also suggests a total budget of only $2.06 million for remediation; comparable remediation projects are estimated to cost up to $8.1 million per instance of groundwater contamination.

“Under the draft permit as written, if water contamination occurred, residents and businesses would likely not be made whole and would not be able to relocate to an area with potable water,” said Anika Juhn, IEEFA energy policy analyst and author of the comments. “In arid Texas, water is a precious resource, and the plan as submitted does not take the proper considerations to protect it or remediate contamination.”

Without proper financial liability determined, taxpayers could be responsible for remediation. The EPA should require additional financial assurances or coverage by a third-party insurer to protect local businesses and residents and ensure they have access to safe, clean water or are compensated fully.