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Keep CO2 Waste Disposal Wells Out of Our National Forests


Since its founding in 1905, the United States Forest Service (USFS) has been entrusted with the vital mission of safeguarding our national forests and ecosystems for the well-being of both present and future generations. However, the Forest Service’s latest initiative has continued to erode trust in the agency’s ability to effectively conserve our forests, and prioritize both environmental and public health over industry interests. On November 3, 2023, the forest service initiated a contentious proposal, aiming to extend access and allow permanent occupancy in national forests to an unprecedented category of users — carbon storage facilities. 

Specifically, the Forest Service is currently seeking to modify the rules governing their “Special Use Permits.” Traditionally, these permits have provided conditional and limited access to our national forests for entities such as outdoor recreation companies. However, the proposed change aims to grant enduring access to industries intending to utilize national forest land for the construction and operation of Class VI underground injection wells. In other words: wells that would be used to capture carbon dioxide from the atmosphere and sequester it deep underground in geologic formations. 

Figure 1: EPA infographic of a Class VI underground injection well

At first glance, this initiative seems like it could be an environmental win. After all, carbon capture and sequestration, or removing CO2 from the atmosphere and storing it in subsurface pore spaces, is a climate change solution that the Biden Administration has backed with billions of dollars of tax incentives and numerous investments. Furthermore, “fighting climate change” is exactly what the Forest Service has said this new rule aims to do. According to the USFS proposal for carbon capture and storage exemption, they claim that “Authorizing carbon capture and storage on NFS lands would support the Administration’s goal to reduce greenhouse gas emissions by 50% below the 2005 levels by 2030.”   However, the fine print reveals a different story. 

While most studies suggest carbon capture and sequestration may prove to be an effective method for mitigating some climate emissions, particularly when implemented near significant emitters, the proposal to permit Class VI injection wells in the national forest raises huge concerns about its potential to fragment or destroy important ecosystems. This possibility strongly challenges the overall sustainability of the plan. Remarkably, the current proposal appears to overlook the existing environment within the national forest that stands to be disrupted by the installation of Class VI wells, the miles of pipeline required for CO2 transportation, and the network of maintenance roads that would surely have to be built for well construction and monitoring. 

As written in their proposal, the Forest Service plans to entirely exclude this special use permit revision from environmental assessments and impact reports. As stated by the Forest Service, “no extraordinary circumstances exist which would require preparation of an environmental assessment or environmental impact statement,” simply because they characterize granting perpetual use to our land as a revision that would qualify as, “regulations that establish service-wide administrative procedures” and therefore are not in a category that requires the agency to take the environmental impact into consideration. 




Besides the obvious neglect of the environment, the movement to remove parts of our national forests to build artificial carbon storage sites holds an obvious contradiction. According to Gabrielle Habeeb, a Forest Advocate at the Natural Resources Defense Council (NRDC), fragmenting or threatening the ecosystems that already act as natural carbon sinks for the purpose of installing an artificial carbon sequestration technology simply does not make sense. “If you really want to create a carbon sink in the national forest,” she commented, “you should be looking at the natural climate solutions already in place.” Mature and old-growth forests on the United States National Forest System are already one of the most effective carbon sinks that we have, sequestering 866 million metric tons of carbon dioxide per year, a quantity equivalent to the annual emissions from 50 million gas- or diesel-fueled vehicles. 

The environment is not the only thing that stands to be compromised by this new rule, public health is at risk too. Concentrated CO2 is an odorless, colorless asphyxiant that is heavier than oxygen and does not disperse well, making it both incredibly hazardous and difficult to manage. Therefore, any potential ruptures in pipelines containing concentrated CO2, or other leaks of CO2 into the environment, could pose a life-threatening danger to all life in the vicinity. The harsh reality of this danger was made tragically clear during 2020, when residents of Satartia, Mississippi experienced a CO2 pipeline rupture that resulted in the evacuation of 300 people, and the hospitalization of 46 soon after. 

Figure 2: Photo by Rory Doyle for HuffPost documenting the site of the 2020 CO2 leak

Despite this dire possibility, the Forest Service has stated that they will permit the injection of CO2 only “in such a manner as to qualify the carbon dioxide stream for the exclusion from classification as a hazardous waste pursuant to United States Environmental Protection Agency regulations.” According to Josh Axelrod, a Senior Advocate at NRDC, safely and effectively transporting and injecting sequestered CO2 is possible, but he emphasizes that this relies on the administration of stringent, extensive regulatory protocols. Unfortunately for this project, proper regulatory protocol do not yet exist. The Pipeline and Hazardous Materials Safety Administration, or PHMSA, is the entity that would be in charge of providing management, inspection, and safety protocols for the pipelines carrying CO2 to injection wells. However, PHMSA’s regulations currently cover only CO2 moved in a “supercritical” state, despite the fact that CO2 in pipelines is expected to often move in a compressed, gaseous state. “They were directed to write a rule over a decade ago and they haven’t done it yet.” Axelrod says, “They say they’re going to do it next year… it’s a mess.” Not to mention, PHMSA classifies CO2 as a “hazardous substance” due to the hazards it poses to humans from accidental releases. This puts EPA and PHMSA at odds, and directly contradicts the Forest Service’s reference to CO2’s “non-hazardous” designation from the EPA, making the regulatory protocol for this project both incomplete and incongruent. 

Figure 3: Photo by Taylor Vidmar for Harald & Review of a Class VI underground injection well built in Decatur, IL by Archer Daniels Midland Co. and approved by the EPA

Confidence in the U.S. Forest Service’s ability to uphold their public safety standards for this project, and protect the environmental integrity of our public lands, has fallen under heavy scrutiny. Since its proposal, more than 140 organizations, including the Chattooga Conservancy, have voiced their opposition to granting perpetual use of national forest lands to carbon capture and storage technologies. These organizations have further called for an extension to the public comment period, a request that, as of now, remains unanswered by the Forest Service. Currently, the public comment window spans over several of the nation’s busiest holidays and ends on January 2nd, 2024, the first workday of the new year. Despite the inconsiderate timing, it is imperative that the public engage in the protection of their lands. To comment against the U.S. Forest Service’s proposal to grant carbon capture and sequestration technologies permanent access to our National Forest System lands, visit the website and speak out!