Board of Zoning Appeals - Regular Meeting

United States of America. I'll make a motion to approve as they are.

Second. Your first case this morning is ZV2603. The petitioner is Vault Alliance and the property owner is Fugate Stock Farms. The property location is the 2,000 east block of 12,200 North and the the request is for variance of development standard setback requirement established in article 21 in 21104 of the McGomery County zoning ordinance and your standard is discretionary. Uh today you'll conduct a public hearing to consider the variance request from the standards in 159 and article 21. Specifically, the petitioner is requesting variance from the required 1,00 foot setback to the parcel line um in a zoning as established in 21104 of 159. Uh notice of the hearing was published May 2nd and also provided to the joining property owners located within 660 ft of the subject property on May 2nd on or before May 2nd. Again, they're requesting the uh variance from the 10,00 foot sack back to partial lines established in 21104. 21 is your carbon sequestration ordinance. It 21 establishes development standards for carbon sequestration and injection facilities. The petitioner has submitted justification for the requested reduction in setbacks in all directions from the property boundaries. In addition, letters of support from adjoining land owners have been submitted in favor of the requested variance. The prop proposed well location will maintain maintain a separation distance exceeding 2500 foot from existing

residences. Uh review by McGomery County Health Department not required. There's no septic involved in this and the existing entrance from 1200 uh was previously approved during imple implementation of the town of Lynen water wells and did not require additional review. The county has reviewed the site for stormware compliance. Uh the development will include approximately 1.5 acres of semi-imperous gravel surface surrounding the injection site. The drainage plan will be reviewed and considered by the plan commission prior to issuance of the carbon sequestration permit and the site is expected to comply with all applicable requirements of the storm storm water ordinance. The property was reviewed for flood plane impacts and no special flood hazard area exists on the site and access is from 1200 north. The property is zoned industrial and you have your your factors to be considered. You have the approval. Will the approval be injurious to public health, safety and morals? Uh number two, the use and value of adjacent properties will be affected substantially in adverse manager manner. And number three, the strict application of zoning ordinance results in practical difficulties. After review, um staff Based on the information provided and the conditions present at the site, staff does recommend approval of the requested variance to the setback standard.

You have to take all three in consideration. But yes, number three does apply. So, good morning uh members of the BCA in Montgomery County. Uh my name is Preston Evans and I work for Vault Alliance uh CCSLP. So, we're on behalf uh we're presenting these petitions uh on behalf of ourselves and Fugate Stock Farms for both the setback requirements and and if I may speak to you know here for the special exception to industrial zoning um for our project. So the subject parcel that you see up on the board um was initially subdivided from a and then recently approved for reasonzoning from agricultural to industrial by the county commissioners. And this is one of many regulatory requirements that we're going through uh before the project can be approved for operation. Um the why that we're here is this project will support the economics of the Lynen ethanol plant allows them to enter into new ethanol markets to sell their products um elsewhere through North America as well as Europe. So it makes them more competitive and keeps them running on a more steady basis. That's the goal. Um, you know, the the project itself aligns with Montgomery County uh comprehensive plan. So, we're augmenting an existing industry. We plan to spend approximately $21 million over the next 12 years to operate and maintain this project and most of that spend is regional. Um, we'll also have a property tax revenue

associated with this of roughly $100,000 per year and we will not be seeking abatement. Uh, so what we're proposing to build on this site, there will be three of our project wells. Uh, our class 6 injection well, which is roughly 6,000 ft deep, a observation well, which is roughly 4,000 ft deep, and a deep uh groundwater monitoring well, which will probably somewhere in the 700 foot range. The average groundwater well in in this part of Montgomery County as well as typic is between 50 to 150 ft. So I'll get into the regulatory bit and you know I will come around to answering why we're looking to set back but it all sets up to uh what we're trying to do. So our this class 6 process is strictly regulated by the EPA water division and their primary mission is the protection of groundwater and that's also our primary mission. Um the project is further regulated by the Indiana DNR. Uh and both agencies have the authority for regular site audits. They have the authority for immediate shutdown and they have the uh authority for requiring annual reports uh detailing all monitoring and sensoring sensing data. I believe in addition uh for Montgomery County will be providing uh our sampling reports as well here. Our injection wells will be high-grade stainless steel used in construction. We'll have 247 monitoring, redundant shutdown systems. Uh and these are all be controlled from the control room. I said 247. You know, safety to us is paramount. Safety integrity of the operation. The injection stream CO2 is nonflammable. As you know, the site won't house any permanent or won't permanently house any hazardous materials other than small

batteries to run to serve as backup power. Our emergency response plan regulated by the EPA addresses all of the scenarios that and the whatifs for this well. So well integrity failure, equipment failure, natural disasters, uh potential for groundwater leak leakage and induced seismic events and potentially fire. Um prior to injection operations, we'll be working with area first responders with our emergency response plan. So this includes the town of London, uh Crawford'sville Fire Department, and the Montgomery County Emergency Management Director. And this will also include yearly drills for uh for preparedness. So, the EPA has had our application since September of 2023. Uh, so it's a fairly long and rigorous process. Um, we came to agreement with Pugate Stock Farms to host this well site prior to that and submitted it. Um, and the driver for Excuse. Excuse me. Thank you. Here we are.

Part of our EPA requirements will be monitoring plume development or CO2 development and that'll require some generators and temporary from a visual impact or a rural impact distance away from the rightway both to the east and some extent to the west farther away west side you know minimizes the visual disturbance on a daily basis might have just one truck visiting the well site per day. So have a fairly light touch. Um and then one last bit about the about the variance for the setbacks. If we were to have to move this project, uh it would set us back significantly with EPA as they consider any move well location a major change. We're already into what's maybe a threeyear process and we expect this would add another year. So in conclusion, you know, this project represents a significant opportunity for economic opportunity for Montgomery County. The Lynden plant consumes over 50% of the corn in the county as well as about 25% or more from adjacent counties. And this is all the while but while while being subject to the most stringent environmental protections available under federal and state law and we also have the support of our adjacent property owners. So I appreciate your consideration and time and I'm here for available for any questions you have about project. Can we

ask questions now? Preston you say it's going to be monitored 247. Is there actually going to be a person monitoring two at the same time? Uh the person will be in a control room. The control room will be remote to the site. Uh so there will be telemetry from pressure gauges both on the injection well as well as the observation well uh that are beamed to a control room where a physical person is watching. But they won't be located. Will it even be in Indiana?

Um we haven't decided yet. It may not be in Indiana. Uh but one of the options is Indianapolis as we've got several projects throughout the state and that's fairly central President I've heard your presentations before the board of commissioners and the plane commission. Um now the BCA kind of your first visit. So, I just want to make sure that I um I want to restate something you said, but in the design of the actual lot, um as I recall, you could have made it 5,000 ft by 5,000 ft, but the comprehensive plan talks about the fact that we want to preserve as much farm ground as we can. So, you had these competing interests, right? Large sight to comply with the thousand foot setback and had this other thing about preserving farmland. So, you intentionally decided make it as small as we can so that we can preserve as much farmland as we can. Is that is that accurate?

Yes. Yeah. Following the the ordinances that that you guys created, we decided to to make the pad itself a small sub parcel so that the rest of the farm can stay as Yes, sir. They should have been included. Yeah.

Preston, for just some contextual background, can you give us a 60,000 foot level of what carbon sequestration is? So, you're you're taking a byproduct of the ethanol plants processes and inject it into the ground here. Is that ignorant question? Is that piped above the ground too? Is it piped under the ground to it? How do you what connects the two? No, that's a great question. Supplying the injection.

So on the Lynen ethanol plant, we'll be taking the CO2 that comes off their fermenttors. If you look at it from the satellite view, those are the the eight big tanks that are on the south side of the plant. Right now, that CO2 is coming out an exhaust stack that's situated right next to those So, we'll be taking the the CO2 from that exhaust stack, routing it to a compressor that will be built and then that compressor will put it under pressure and we'll put it into a pipeline that will be buried and run from the plant a little bit to the north and then do east out to the well site. So, that pipeline's under the regulatory control of the DNR as well as DOT, but nominally it's beared from six feet to as much as 25 ft depending where we're at. Uh but you won't see that pipeline after after construction. We'll be 25 ft under the railroad more than 10 ft under the road and will be well underneath all the drainage uh the regulated drains and ditches that are in the area. So that comes out to the well site. top of the injection interval is 4,200 ft deep mid depth call it a mile where we'll have CO2 be and we sit on unique geology the middle of Indiana is very conducive to this there's a formation that runs from middle of Ohio to western Illinois as far north as Wisconsin and down to Kentucky called the Mount Simon. So it's this regional sandstone

that's been used for disposal operations since the 60s for class one wells. So a lot of the steel plants, a lot of the refineries use this form for spent acid steel process side and waste water on the refinery side. We do have to buy access. Um, right now we've bought 93% of our access and we lack one land owner who's an absentee land owner that we're still working with. Uh the pipeline is carbon steel. Um CO2 in its in the in the pressurized state is it's not corrosive. It's only when it mixes with water in an unpressurized state doesn't have corrosive properties. It'll be a mix of both. Um where we are crossing open farm ground are to be trenched. Uh but where we're crossing any of the public rideways or or private rightways like the railroad, they'll be either drilled or bored.

No, it'll be coated with epoxy epoxy resin. Uh so the whole pipeline's coated with epoxy. At the inlet and the outlet, we'll have monitoring stations that sense either pressure change or change in flow or um even decreases in in flow rate will trigger shutdowns for this pipeline. You had mentioned earlier about plume development. What is that?

Yeah, sorry. I'm the engineer so I speak in sometimes I go uber technical because I live this world. Um plume develmentvelment.velmentvelmentvelmentvelmentvelmentvelmentvelment.vel element is is what we what we phrase as the extent of the CO2 underground. Uh so as you're right now in this Mount Simon formation, there's a just salt water exists. And so as we inject CO2 into this, it will push the salt water away and replace it with the CO2 that we're injecting. So the plume is the CO2 as we're pushing it out. you know, roughly over 30 years, if the project goes that long, um, we see plume development of approximately a mile radius from the center of the well with 90% of that being within a half mile.

So, does that create an oval shape down there or can you monitor to see exactly how it's going?

Yeah, absolutely. No, we monitor it in several ways. So, We'll also have That's number two. So, you're only going to have two monitoring wells in one right close by and then another

system to ensure that CO2 is so down for and then we've got about 600 ft of dense shaleed Just above that is another salt water that will shallower and it purpose is to monitor the pressure in that water to make sure that none of the CO2. above that several more.

So just those two wells are enough to be able to monitor the entire development.

That's correct. In oil and gas world two wells is a luxury and so my background high pressure injection injection in those worlds where we just use the single well injection to tell what's going on. So every year we'll be running pressure test allows us to see a bit farther out the reservoir from the injection well both wells can do it allows you to see where the CO2 is going see how the reservoir pressure is changing plug that reservoir models that we maintain allow us to model out where it's going and that's confirmed with the offset deep observation also All right. Anybody else have any questions?

Great. Thank you very much.

Public hearing. Okay, we're going to open up public hearing 11:24. Anybody want to come up and speak? Just come up and identify yourself and state your opinion. We have any. So, I guess we're closing the public hearing at 11:24. Okay. Now, um is anybody ready to make a motion? And then we discuss some more step. We know these guys can't do it unless they have right now they have to have that thousand foot where they are there's no way they can get foot where they're sitt

I mean as far as this case goes with having the owners signed off that I don't see motion that we approve.

Yeah, I'll second that. Okay, we have any other discussion to you guys ready to vote? Okay. All those in favor of the variance to allow their exemption say I.

All opposed. Okay. Looks like we got Okay, you guys are good this time. Okay, now Mark, what's our next situation? It's going to be very familiar. This is uh case number 2026-1. The petitioner Alliance and property owner is Fuggate Stock Armed. Again, the property location is at 2000 East block of 1200 North and the request is for a special exception to the industrial classification in the use table of chapter 159. Today, you'll conduct a public hearing to consider the request for the special exe exception pursuant to table A of M of chapter 159 of the McGomery County zoning ordinance. petitioner is requesting approval for a special exception associated to the in industrial classification. Special exceptions are reserved for land uses that may have significant impact on the zoning district or the community as a whole or for uses that require additional safeguards and review. These safeguards are established to the specific standards and criteria outlined in the zoning ordinance. The applicant for special exception must demonstrate compliance with all applicable standards and criteria contained within the ordinance. The petitioner has submitted documentation demonstrating compliance with article 21 of the zoning code with the exception of the variance previously considered by the board which you did approve. A special exception is considered an appropriate land use within a zoning district when it can be demonstrated that the proposed use will not adversely affect public health, safety, and welfare and will comply with the aptable standards established in the zoning ordinance. The zoning ordinance authorizes the BCA to hear and decide applications for

special exceptions in accordance with these standards and criteria. Um, with that information, the petitioner submitted the required information and materials necessary for review of the special exception request. And based upon that information provided and the conditions present at the site, staff does recommend approval of the request special exception.

Okay. So, we ready to listen to the petitioner? You're on Preston. Well, I um I don't have much to add from my my previous uh speech, but I would uh you know, obviously here for questions as it regards to the special exception.

I guess I just have to what exactly is this special exception? Uh the u your zoning ordinance has a chapter on carbon sequestration and it says that it it has to be um has to receive a special exception approval from you. So this is a this is done when there is a use that requires a little extra look at it. Make sure we have safety. In 412 of the ordinance, excuse me, it gives you help on what what are we supposed to be looking at here? Uh so the first criteria is is this something that the board of commissioners has said could be a special exception. It has to be specifically listed. This use is specifically listed. So that so so the first criteria is pretty easy. The second one mainly the rest of it deals with impact. So will the granting of the special exception be detrimental to public health safety and general welfare? That's that's really the first step. Secondly, will it be used will the use be injurious to the use and enjoyment surrounding properties. Third, will be adequately served by essential facilities, meaning roads, utilities, that sort of thing that are going to be are going to come along with that use. Fourth, uh that the granting of the special special exception will not create excessive additional requirements of public expense. So, we're not going to have to build a road here. We're not going to have to uh the county is not going to have to build a water line there, for example. that that sort of focus. Uh fifth, they can't if they had a previous denial of a special exception, they have to wait a year before they come back. So that's always a question. And then those are the required uh factors to be looked at. In addition, the statute the ordinance says that you may in addition to those look at some other things and those those three additional factors are in what

respects the proposed special exception meets the requirements and standards of the ordinance. Now, Preston and and the petitioner spent a lot of time telling you how they have complied with the requirements of the ordinance as it relates to specifically to carbon sequestration. Um, and again, it appears they're in compliance with that and uh I agree with Preston, heavily regulated by our state environmental organizations and the EPA and a very long process. Um, so but but they have to in addition everything else they have to comply with our ordinance every aspect of it and and again I don't see any information that they've not the second one is the the method by which of the proposed special exception makes adequate provision for public services controller of vehicular traffic and furthers the amen amenities of light air recreation. Uh this is mainly if you think about this going to be a factory built or something really large. We want to look at that and make sure that they're managing the on-site use and they're and they're they're making it better not worse. This is a very this particular use is very small and like footprint and it's kind of out away from everything and again the public's not being burdened by to get them to their site or to deal with traffic on their site. And the third um and the third additional factor is whether the proposed special exception is in accordance with the general objectives and findings of the comprehensive plan. So in this process uh for their platting and for uh you know their their petitions before you today you've heard about how in uh shaping this proposal they were also influenced by the other requirements of the comprehensive plan to preserve agricultural land to not make that footprint any larger than it needs to be uh to be you know is this use you know again I think that because it's listed as special one of the things is this use

Is it consistent with a or is it not? Again, I think the policy of the order commissioners expressed in the comprehensive plan is that this is a use consistent with a the county commissioners have specifically listed undesirable uses and this use is not on that. This is a use that county commissioners believe fits in with and could be beneficial to individual land owners who are probably going to be farmers and also as Preston mentioned earlier very beneficial to at least one of our businesses here locally. So uh so number three about like is this is this the is this in the right place? I think I think there's evidence that that no major concerns in these last three. So again, the criteria for a special exception says, "Hey, look and make sure there's no detrimental impacts to the area. Make sure it's not going to be injurious to anyone. Make sure that um it's not that their project's not going to put incredible uh burdens upon the government to make that work." And so that's the focus. And then a reminder from training, as you guys know, if they can meet that criteria of 4.12, you have no discretion. So if you they can meet that then you have to say yes. If you find that they can't satisfy it then you then you say no.

Okay. Have any questions? Yeah. Um, so I, you know, I've read through the packet on all the, you know, the monitoring wells and everything that you walk through. Um, and I get watching or you know, making sure something doesn't go wrong, but like what happens when like you're obviously watching for a reason there's a risk. What happens if something goes wrong? Like what can go wrong and what is the remedy if something goes wrong with these wells?

Sure. Let me start though with well construction. So these are pretty high-end wells where we'll be drilling down said 6,000 ft for the injection well and there will be three concentric rings of steel. All of those cemented into place. Uh then in addition there's a fourth inner ring that's our tubing. It's our injection pathway. And the the annulus between the tubing and the first casing steel is liquid filled and pressure monitor. So the first thing that can go wrong is a leak in that tubing. And we see that immediately through pressure monitoring at the surface that's being back to a control room. That triggers a shut down. So think about those strings of concentric rings of steel as as redundant safety safety measures. So if the first one fails, then we shut down injection, flush the well with water, and we come back and fix that. In addition to that, we're we're watching annually to see if there's any leakage of that CO2 behind the steel, so in the once you get behind there, then there's two more layers to go, two more layers of protection to go to. So that's on the well itself. Um in addition the observation wall that's on this well site will be looking for any kind of CO2 leakage through the primary confining. So if that sees pressure response so indicating CO2 has come up and changing the reservoir then we shut down injection operations and we have to go back to figure out why this is why this is happening. If we can stop it then we can restart but we stop it. Project's done. So that's down deep. That is at the 4,000 foot level. Literally,

you have several layers of of of formations to go before you get up to groundwater. But then also, we have a deep groundwater monitoring well. So if you think about the groundwater around here is not in one big giant aquifer. in what are called venticular clouds of aquifers where they're not always connected and they're not laterally extensive. So if you drilling at 80 ft on one property and get water, you might be able to drill at 50 ft another property or down to 120 ft water. You may not see that 80 foot layer, just one parcel. So, we'll be drilling a deep deep deep uh water well uh to monitor for in the event of CO2 coming up that we're not able to detect in any other way, uh it would see it first. And then beyond that, we're also sampling water wells in the broader area. radius around the injection be sampling twice a year to see for any contamination.

And how does that process work with land owners?

Uh we have to sign access agreements or we we have to go find land owners that were willing to give us access agreements to go test the water. Uh we've done that. Um and we'll be doing roughly 15 call it 12 to 15 wells twice a year under injection. test. So if one of those sees a change in parameters, then that's also a signal to shut down. We haven't seen it in any other of our surveillance technologies both continuous and annual. That's a signal to shut down and then we have to go and remediate the groundwater for the affected land. And primarily for CO2 contamination, it's a filter at surface that we have to If that doesn't work then there's an extreme case it's us responsible for providing water for that particular and we provide we have to post financial assurance to the EPA as well as the state to provide like in the event we're not here in the something weeks then that money is used to support the land owners for

it's obviously so I I guess the the pipe going through the water layer. What's that look like as far as the well that goes through the water layer itself? Like could it first happen at the water layer? Um theoretically it could uh but the the design factors on all of the the pipe steel so to start with the design factor on the tubing itself is I think two to 3x what the compressor can deliver. Um, in addition, the first layer of steel also has a similar burst rating. So, I want to say our seven inch casings first big deep cemented string. Uh, it's going to be in the 5,000 PSI burst range. The normal operating pressure is 1400 PSI. The compressor can't go over 2,00 2200. So, we have roughly a 2x safety factor. first training that's in primary primary and secondary. So in some I don't trying to think of the uh the nature of the event that could burst the all three strings of pipe at the water obviously most of us are familiar real familiar with this process but you know you get online and You know that's that's one of the concerns with risk ground but the the risk for seismic activity comes up a lot as far as

Yeah, that's a great question. So in in addition to the the well monitoring and the seismic monitoring, we'll be positioning five seismometers local to this area within about a two mile radius of the well. And the seismometers allow us to activity that is beyond what we can feel. So we can feel roughly two to 2.5 magnitude earthquakes. That's you standing next to a railroad track or outside of the Colt stadium during a game. But we can see these seismometers down to at least magnitude one or below. So if if our injection is causing seismicity, then our local seismometers see it first. and allow us to shut down, evaluate, and potentially change what we're doing before we cause anything that can be even, you know, minorly felt by by humans. Um, we are not allowed by permit to cause earthquakes. So, we've got a risk register with the EPA where we also turn in the seismic data to them as well as the state and says, "All right, do you have any seismic activity?" Yes or no? Yes. What's magnitude is it below the felt level? If you have above felt level, you have to shut down and

That's correct. This is the third year of the permit. So we do anticipate a decision from the EPA up or down um by December of this year and then we would start construction in first quarter of 2027 and potentially be online in fourth quarter end of 2027. I guess the third risk that I saw it seemed like seal and release all the injected CO2 back into the atmosphere back up through the

um that yeah that's a possibility. Um you know again uh it starts with the design factors. So the whole well is designed 2x what the possibilities are um you know from a if we were to to lose containment you know at surface for example and the reservoir were able to flow then it would be a well blowout situation where CO2 is coming up salt water is is partially preventing that CO2 from coming up but we would have to come in and remediate that with a work rig Fix it.

What would be?

Yeah. If we had above ground loss of containment from the reservoir, uh we would have CO2 dispersing at surface depending on the angle that comes out. So the well is a series of valves both vertically and horizontally. And if the horizontal end cuts out, then you'd have a CO2 release in the horizontal direction. It cut out in the vertical then it would go out vertically and settle back down. The worst of those two is a horizontal release because that CO2 directly at the 10 foot level going out. But that worst case for this well is roughly 700 feet in the in the downwind direction. So the location of this particular well site is such that that doesn't endanger general public. That's just from the injection well. The other wells don't have the same profile if you will for release. And so in the event of a release you have the volume in the tubing. I'm going to get super technical here. a compressed volume in the tubing that releases and causes a bigger dispersion and then you have a reservoir flow that follows that back up. So the initial release is in the 7 to 800t range and then that comes back down as the reservoir flows to the 300 range. I mean it comes up as it chemically into something it doesn't. Um, so the initial release would be probably have a bit of dry ice with it. But as the reservoir flows and you have less of a pressure drop, it would just be CO2 that then returns to the atmosphere. The CO2 does not dispute.

It depends on the timing. So really early there is salt water closer to the the well itself and that CO2 just like your soda stream at home or pot the thing CO2 goes into solution with the water but as time goes on we push the salt water away from the well and all relatively dry CO2 um in the reservoir the salt water pushes And so we consider the Mount Simon a infinite acting aquifer and that means something like think about Lake Michigan. If you were to drop a new boat into Lake Michigan, there is a displacement of that boat from the lake. But because the size of that boat is so small relative to the lake it earlier.

We're not trying to recover something.

That's right. Yeah. In a past life, we had a CO2 flood in southeast Utah and you'd have an injection well and production or a series of those and you push injection CO2 into one side and it's missable with the oil. So it picks up the oil as it goes by and typically the oil saturation at that point is so low that the oil is the small molecule inside the injection stream. Then you produce it out the other side. You run it through a separator mechanical separator. Oil drops out. Take that CO2. That's right. So in this case because the aquifer is infinite relatively infinite it just pushes the pushes out.

That's correct. Now the CO2 coming off the fermenttors from ethanol production is about as pure as you get in the industrial world. Our permit is 98% but typically the stack samples at 99% CO2 contamin.

Yeah, that's a good question. Um so vault is a fairly new company you know in it in itself but our members are well experienced in the CO2 world. We've been a part of the ADM Decator wells as well as several projects up in Canada and then throughout the world from our past experiences, my past experiences. But Vault itself, we're drilling our second injection well as we speak over the east side of the state. Probably by year end we'll have seven wells drilled in the in the Midwest that are both owned and operated. So on part of our packet we got

Yeah. No, that's a great question. Um, so the Decada project started in 2011 and it started with a lot of POE money but a lot of science to go and prove that this is a commercially feasible technology. Well, at least prove it to in the Midwest setting. CO2 injections been going on since the late 70s in E projects throughout the United States. Um, so the the configuration of the decator wells had more had a lot of complex widgets in it and we've got a much simpler well construction method. The leak that they had was in one of their observation wells and they had an observation well that was sampling both the Mount Simon reservoir as well as the above shallower reservoir. So it was trying to do those simultaneously. And just over time they developed a leak in the tubing from the monitoring of the deep reservoir to the monitoring of the less deep reservoir allowed CO2 to escape from one point to another. Once they determined that then they were part of their protocols they shut down and said we've got a leak. You know this is one saltwater reservoir to another. So at no time was any groundwater in danger. the system working. Um they have since gone and plugged those wells and gone to a more simpler, keep it simple, stupid method where we've got our dedicated deep injection well. It's only monitoring the deep reservoir. It will also be using highend stainless steel. It doesn't do anything else. And then we've got the shallow monitoring well that's not connected to the path.

Okay, we have any more questions? Sorry, I wrote down a few. No, these are great questions. Appreciate them. Okay. No, I I don't have any questions. the I guess the the escro risk. It looked like in the paperwork that there's an escro for demolition of the site should injection stop it back to its natural state. That's what I understood by reading that you were saying there's an escrow for contamination relief.

So the escrow covers a number of different things um in the event that goes away. uh it covers the remediation of the site. So the full plugging of the site, but also as a part of the EPA process, you're required to monitor the whole area for 50 years after after the end of injection. So it's money to provide for that monitoring over those 50 years and then at the end of those 50 years the wells. So the escro contains that pays for somebody that contract to go and conduct all these activities over that time period. So that's one chunk. There's another chunk that's an insurance policy and the insurance is the piece that covers what groundwater contamination or it covers all manners of leaks and remediation to those all summed. I think 13 and a half 14 million and those are those aren't like they don't go into the general kitty for EPA. We've had questions like this before the agreements with the financial providers are that it's only for the purpose of EPA to use on these specific wells cannot be used for anything else and I guess the overall reason as far as how does that process and what spending $21 million makes?

Yeah, good question. Um, so it it allows them to market their products to a broader network. So if they're only And you know, Valero is isol, but if they're only selling to the US ethanol market, the standard blend that you go get at the pump, it's just one market and that es and flows. Right now, it's quite flowing, but other times it's eb. And so by lowering the carbon intensity of ethanol they produce makes them eligible to sell to Canadian markets or European markets that say we would like a portion of our fuel to be lower carbon. So it expands the market opportunities to sell on a more consistent basis to make up the flows of standard US energy. There is an input cost to compress. Probably our our the project's biggest piece of opex is electricity for the compressor. That'll be handled through tip and electrical provider. But that goes into the carbon intensity score of the ethanol itself. So it's factored into the output for I just budget.

Anybody else have any questions while we're done here? I think that'll do for now. Okay, great. We still need to open up for a public hearing. Public hearing will open at 11:56. Is there anybody here would like to come up? And looks like we got the same crowd. So, I don't think we got any takers. So, I guess we'll close the public hearing at 11:56. Okay. Well, if we're done with questions, we ready to make a motion to approve or

Yeah, I'll go ahead and make a motion to approve the special

variance. Okay. Need a second. Okay, we got a motion and a second. All those in favor say I. I. All oppose. I Well, we have passed. Okay. Very good. You're two for two. You bet. Okay. Do we have any anything else on the agenda, Mark? Okay. How about you, Dan? You have anything you need to tell us about? Well, I guess uh we're done for the day. I need a motion to adjourn.