Louisiana - Louisiana Governor Jeff Landry has ordered a moratorium on new carbon dioxide storage well applications while directing state agencies to concentrate on five priority projects already in the permitting pipeline, according to Executive Order JML 25-119 issued by the governor's office.
The executive order, which took effect upon signing, suspends review of any new Class VI well applications submitted after the order's effective date. Class VI wells are specialized underground injection wells designed exclusively for the long-term storage of carbon dioxide in deep geologic formations, regulated under the federal Safe Drinking Water Act.
The Department of Conservation and Energy, which was renamed the Department of Energy and Natural Resources, has received 33 applications for carbon sequestration projects since Louisiana obtained primary enforcement authority for Class VI permits. Each application requires approximately 2,000 hours of review between submission and a permit decision, according to the executive order.
Louisiana is one of only five states with primacy to issue Class VI permits, joining Arizona, North Dakota, West Virginia and Wyoming. The state is the only one with this authority in the U.S. Environmental Protection Agency Region 6, though neighboring Texas is expected to receive approval for Class VI permitting in the near future.
The five projects prioritized for continued review are Hackberry Sequestration in Cameron Parish, Capio Sherburne CCS Well #1 in Pointe Coupee Parish, CCS 2 – Wilcox2 in Vernon Parish, Goose Lake and Minerva South in Calcasieu and Cameron Parishes, LGF Columbia in Caldwell Parish, and River Parish Sequestration – RPN 1 in Ascension Parish.
According to Department Guidance No. B-2025-01-A, issued by Secretary Tyler Gray on Sept. 1, 2025, the Class VI review team will concentrate on these applications following issuance of the permit for Hackberry Sequestration.
The executive order requires coordination between the Department of Energy and Natural Resources and Louisiana Economic Development to evaluate the economic potential of projects associated with Class VI applications. This includes reporting on projected economic impact, local and regional economic growth, workforce opportunities and any community benefit plans adopted by parish governments.
Louisiana Economic Development data cited in Department Guidance No. B-2025-01 shows that new energy and industrial emissions reduction projects have attracted $61 billion of investment and created 26,952 new jobs. An economic analysis performed by the Rhodium Group for the Regional Carbon Capture Deployment Initiative estimates that deploying carbon capture at 33 industrial and power facilities in Louisiana could create an annual average of up to 4,920 project construction jobs over a 15-year period and 2,500 ongoing operations jobs.
The executive order states that carbon dioxide capture and storage will extend Louisiana's presence in energy by creating 17,000 potential new jobs and investing $76 billion in potential capital for communities throughout Louisiana from announced projects alone.
According to the executive order, Louisiana has injected carbon dioxide into geological formations for enhanced oil recovery projects for over 40 years, and carbon dioxide has been safely transported via pipelines across the state since 1986. The state's geological formations provide 753 billion metric tons of safe storage potential for carbon dioxide, according to Louisiana Economic Development.
The executive order requires applicants to demonstrate compliance with comprehensive safety and environmental standards before permits can be issued. These requirements include gathering pre-application data, completing application components found in Louisiana Administrative Code 43:XVII.3607, emergency operations plans, well control procedures, and identification and mitigation of any existing wells that could pose risks.
For pipelines transporting carbon dioxide to or from Class VI wells, operators must adhere to existing requirements found in Louisiana Administrative Code 33:V and any forthcoming federal carbon dioxide pipeline safety standards currently under Pipeline and Hazardous Materials Safety Administration rulemaking. Where provisions have been delayed at the federal level but are consistent with Louisiana regulations, the Department will require equivalent protective measures, including remote or automatic shut-off valves, robust emergency planning and corrosion-control protocols.
The executive order establishes what it calls Louisiana's Landowner Bill of Rights for Geologic Sequestration Projects, based on Act Nos. 407 and 414 of the 2025 Regular Session. These laws require the Department to give substantial consideration to oral or written comments submitted by local governments in any matter requiring public comment or a public hearing.
The Department must document in writing all relevant local government concerns received and demonstrate how these comments were taken into account in permitting decisions, according to the executive order.
The typical timeline for reviewing Class VI well applications spans approximately two years, according to Department Guidance No. B-2025-01. The process includes an administrative completeness review of one to three months, technical review of approximately 18 months for a complete application, a public comment and hearing period of at least 30 days, and several months for post-comment revisions and final decisions.
The Department has updated its application tracker system to align with U.S. Environmental Protection Agency practices, with categories including completeness review, technical review, draft permit preparation, public comment period and final permit decision preparation.
Louisiana's refineries account for 16% of the country's refining capacity, and the state's network of pipelines transport 90% of the nation's offshore energy production and 30% of the total oil and gas supply, according to the executive order. The state produces the second-largest volume of oil and gas in the United States.
The United States became the world's largest liquefied natural gas exporter in 2023, and the U.S. Energy Information Administration forecasts U.S. liquefied natural gas exports to average 13.7 billion cubic feet per day during the 2024-25 winter, 8% more than the previous winter as new projects come online.
The 2024 Gulf Coast Energy Outlook notes that announced energy transition investments across the Gulf Coast total $79 billion, representing 36% of all energy manufacturing investments projected for the next decade. Between 2011 and 2022, the Gulf Coast saw $212 billion of investment in refining, chemicals and hydrocarbon exports, 50% of which was in Louisiana.
All communications or inquiries regarding Class VI permit application status or related information must be directed exclusively through the email address [email protected], according to Department Guidance No. B-2025-01-A. Direct communication with departmental personnel for application updates or status inquiries is strictly prohibited.
The Louisiana Legislature passed Act No. 517 of the 2009 Regular Session, the Louisiana Geologic Sequestration of Carbon Dioxide Act, granting the Department authority to promulgate rules, regulations and issue orders and permits. Class VI wells must comply with Louisiana's Statewide Order No. 29-N-6 and the Safe Drinking Water Act of 1974.