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Sarah Milocco

Sarah focuses on real estate law, primarily in the renewable energy sector.

Prior to pursuing a legal career, Sarah earned a master’s degree in Energy and Earth Resources and worked as a carbon capture and sequestration researcher, which required extensive knowledge on all forms of energy. This technical background allows her to approach issues from both a legal and scientific perspective, especially in the area of carbon capture. In fact, her decision to attend law school was driven partly by her observations during her time as a geoscientist that there was a great need for legal professionals with technical and scientific backgrounds in energy.

As a law student, Sarah took every energy law class available and served as the Recent Developments Editor for the Texas Journal of Oil, Gas, and Energy Law. She also discovered a fascination with property and worked with a property/energy professor during her first summer, further solidifying her interest in the renewables sector. Sarah also spent a summer as a summer associate at Husch Blackwell, working primarily on energy-related topics with the Real Estate & Development and Energy Regulatory teams.

Known for her research capabilities and technical background, Sarah is highly knowledgeable and efficient. Her unique blend of legal and scientific experience makes her a valuable asset in the field of energy law.

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Carbon capture and storage (CCS) is rapidly emerging as one of the most consequential areas of energy law and environmental regulation. At its heart sits a technical but critically important regulatory category: the Class VI injection well. These wells are used to inject carbon dioxide into deep rock formations for the purpose of long-term underground storage, making them the cornerstone of any commercial-scale CCS project. For years, permitting authority for Class VI wells located in Texas rested solely with the federal Environmental Protection Agency (EPA), resulting in a process many in the energy industry found slow and uncertain.

That all changed last fall. In November 2025, the State of Texas formally received primary enforcement authority, or “primacy”, for its Class VI Underground Injection Control (UIC) program, granting the Railroad Commission of Texas (RRC) regulatory power over these types of wells and, consequently, the CCS process.

This article examines how Texas achieved this milestone, how the state strategically positioned itself for a seamless transition by accepting applications and fees years in advance, and the status of those permit applications today.

Introduction: CO2-EOR vs. CCS

In recent years, the importance of carbon capture technology has grown significantly as a means to combat climate change. With the emergence and advancement of geologic technologies, and their application in the energy industry, many industrial companies are deploying both CO2 Enhanced Oil Recovery (CO2-EOR) and…

One promising solution to climate change is Carbon Capture, Utilization and Storage (“CCUS”). CCUS involves capturing carbon oxides, primarily carbon dioxide (CO2), for permanent storage or potential utilization. Interest in CCUS increased after the Inflation Reduction Act (“IRA”) revamped Section 45Q of the US Tax Code to expand tax…