Trailblazer Pipeline Company LLC is one step closer to transporting carbon dioxide following the FERC order

In the year On October 23, 2023, the Federal Energy Regulatory Commission (FERC) ordered Trailblazer Pipeline Company LLC (Trailblazer) to convert its approximately 400-mile long natural gas pipeline system to carbon dioxide (CO).2) transportation. Trailblazer plans to transport the pipeline, originally put into service in the 1980s, from the limited Rocky Mountain supply basins in Wyoming to bring it to Nebraska, CO.2From ethanol plants and other sources of emissions in Nebraska and Colorado to Wyoming permanently in geological formations (the Trailblazer Conversion Project). FERC has no jurisdiction over CO location, construction or operation2Pipe lines. But Trailblazer requested FERC approval under Section 7(b) of the Natural Gas Act (NGA). The order also authorizes Rockies Express Pipeline LLC (Rockies Express or REX) to construct additional facilities under NGA Section 7(c) and allow Trailblazer’s existing capacity to continue serving Trailblazer’s natural gas transportation customers. Trailblazer also intends to enter into a contract with Tallgrass Interstate Gas Transmission, LLC (TIGT) to serve its strong customers. All three pipelines are operated by a subsidiary of Tallgrass Energy Partners.

FERC conducted an environmental review of the Trailblazer conversion project under the National Environmental Policy Act (NEPA) to remove the pipeline from natural gas transportation service and award Rockies Express a new natural gas transportation service contract. On the REX system. It did not assess the environmental impact or benefits of transporting CO.2Because this future use is illegal. FERC also noted the lack of pipeline safety regulations on CO transportation2In a gas, in contrast to the supercritical fluid state. The U.S. Department of Transportation, the federal agency charged with overseeing pipeline safety, is developing regulations for the Pipeline and Hazardous Materials Safety Administration, but does not expect to issue a notice of proposed rulemaking before June 2024.1

CO2Pipeline transportation is not widespread in the United States, and until recently, was typically used only to transport CO.2It is used for improved oil recovery.2 through the development of carbon capture and sequestration technology and decarbonization incentives and laws such as the Depreciation Act;2The pipeline network is clear. However, since there is no federal licensing authority for CO2Similar to FERC’s NGA authority over natural gas pipelines, permits to construct, construct and operate new pipeline projects must be processed by state. The Trailblazer conversion project is unique among other multi-state COs.2Pipeline projects under construction are based on existing pipeline infrastructure, unlike greenfield pipeline construction, which removes some of the hurdles from the permitting process. Days before FERC authorized Trailblazer to abandon natural gas services, greenfield pipeline developer Multistate CO.2Cancellation of pipeline project due to state permitting issues.

The Trailblazer conversion project will also benefit businesses by having a terminus in Wyoming. Wyoming is one of two states to receive regulatory priority for Class VI wells under the Environmental Protection Agency’s (EPA) Safe Drinking Water Act’s Underground Injection Control Program. Class VI underground injection wells are used to inject CO2For geological sequencing. Projects seeking to acquire Class VI wells in non-priority states may require a longer review period given the number of projects pending before EPA. Based on its ultimate success, the Trailblazer conversion project could become a model for other COs.2Pipe conversion projects.

1 look out Congressional Research Service, Carbon Dioxide (CO2) Pipeline Construction: A Federal Initiative (Jun. 2, 2023), available at ,goals%20for%20reducing%20greenhouse%20gas%20.

2 According to the Congressional Research Service, there is approximately 5,000 miles of CO.2pipelines in the U.S., compared to roughly 3 million miles of natural gas pipelines, according to the U.S. Energy Information Agency catalog.

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