API’s New Rules Reveal a Credibility Problem, Please follow their Substack Link at Bottom of page.
There’s a quiet moment every industry reaches when it has to decide whether its principles are guardrails or décor.
The American Petroleum Institute has long presented itself as a defender of free markets, private property, and innovation driven by competition rather than compulsion. Its principles are clear, well-written, and familiar to anyone who has spent time around energy policy debates.
And yet, with the release of API Recommended Practice 1192, a standard dedicated to the transportation of carbon dioxide by pipeline, something subtle but important has shifted.
Not loudly.
Not illegally.
But unmistakably.
This isn’t a question of safety. Engineers should always pursue safer systems. This isn’t even a question of intent. Institutions adapt. They always do.
This is a question of alignment.

“Promote free markets and free trade as the cornerstone of our industry’s efforts…”
That line has always mattered. It’s the philosophical anchor — the idea that energy infrastructure earns legitimacy through voluntary exchange, price signals, and risk discipline.
But CO₂ pipelines, as currently structured, do not emerge from free markets. They emerge from policy architecture.
Their economics depend on:
- Federal tax credits
- Government-backed loans
- Grant programs
- Regulatory accounting
- And, in many cases, compulsory access to private land
API RP 1192 does not promote market competition between routes, projects, or technologies. It promotes standardization to make government-backed deployment smoother.
That’s not a market failure.
It’s a market substitution.
And once markets are substituted, standards stop being tools of competition and start becoming tools of normalization.
“Support risk-based, cost-effective government regulation…”
This principle once meant resisting unnecessary regulation. Today, it increasingly means anticipating regulation and building it into the system ahead of time.
RP 1192 is voluntary on paper. In practice, it will become:
- A permitting reference
- A litigation benchmark
- A financing prerequisite
- A liability shield
When public money enters the equation, voluntary standards rarely stay voluntary. They become expectations. Expectations become conditions. Conditions become enforcement.
That’s not risk-based regulation.
That’s risk distribution — away from institutions and toward landowners and taxpayers.

“Advance safe and responsible petroleum and natural gas production, transportation…”
Here’s where the language gets stretched.
CO₂ pipelines do not deliver energy. They do not reduce consumer prices. They do not increase reliability. They exist primarily to enable compliance markets and credit monetization tied to regulatory frameworks.
There’s nothing inherently wrong with that — but it is categorically different from advancing energy abundance.
RP 1192 quietly repositions API from an energy trade association to a carbon infrastructure facilitator, without updating the philosophical justification for that shift.
Safety standards without market legitimacy don’t strengthen trust. They merely harden process.
“Commit to integrity… transparency… accountability…”
This is where landowners notice the silence.
RP 1192 is meticulous about:
- Pressure cycling
- Fracture control
- Corrosion mechanisms
- Emergency response
It says almost nothing about:
- Easement valuation fairness
- Long-term landowner liability
- Credit permanence risk
- Reversion if carbon markets collapse
- What happens when pipelines outlive subsidies
Integrity, in this framework, ends at the pipe wall.
For landowners asked to bear permanent encumbrances on finite property, that omission isn’t academic — it’s structural.
What this standard actually accomplishes
Let’s be clear: RP 1192 will improve technical consistency. It will help competent operators design better systems. It will reduce ambiguity inside the industry.
But its primary function is not safety alone.
Its primary function is legitimization.
It allows developers to say:
“This is no longer experimental. This is standardized.”
It allows regulators to say:
“This meets industry guidance.”
It allows financiers to say:
“The risk has been normalized.”
What it does not do is restore balance between public ambition and private property.
The free-market tension API hasn’t addressed
In a functioning free market:
- Routes are negotiated, not imposed
- Risk is priced, not socialized
- Projects rise or fall on voluntary participation
- Standards emerge from competition, not compliance
CO₂ pipeline infrastructure today operates in a different ecosystem:
- Subsidy-first economics
- Mandated access
- Political urgency
- Legal insulation through standardization
RP 1192 didn’t create that system — but it cements it.
And once cemented, it becomes very difficult to distinguish public interest from institutional momentum.
This isn’t an accusation — it’s a warning
API didn’t abandon its principles overnight. The environment changed. The money changed. The incentives changed.
But principles that aren’t recalibrated become ceremonial.
If API wants to maintain credibility with landowners and free-market advocates, technical standards alone are no longer sufficient. The conversation has to widen — beyond metallurgy and pressure curves — to include consent, compensation, and long-term accountability.
Otherwise, standards become what they were never meant to be: permission slips for power.
What API RP 1192 Does Not Protect You From
API Recommended Practice 1192 is often cited as a safety benchmark for CO₂ pipelines. What’s less discussed is what it intentionally leaves out. If you’re a landowner, here’s what this standard does not address or protect you from:
❌ Eminent Domain
RP 1192 does not limit or question a developer’s ability to pursue eminent domain.
If a pipeline qualifies under state law, this standard does nothing to prevent compulsory easements.
❌ Easement Valuation or Fair Compensation
The standard does not address:
- How easements are valued
- Whether compensation reflects long-term risk
- Market vs. statutory pricing
- Re-negotiation if project economics change
Engineering consistency does not equal economic fairness.
❌ Long-Term Landowner Liability
RP 1192 does not clarify:
- Who is liable if CO₂ leaks decades later
- Whether landowners could face secondary claims
- How responsibility is handled after ownership transfers
- What happens if an operator dissolves or sells the asset
The pipe may be standardized — the liability is not.
❌ Project Failure or Market Collapse
CO₂ pipelines depend on:
- Carbon credit markets
- Federal tax incentives
- Regulatory accounting rules
RP 1192 does not explain:
- What happens if subsidies expire
- Whether easements terminate
- If land is restored
- Or who pays if the pipeline becomes stranded infrastructure
Permanent easements can outlive temporary markets.
❌ Transparency Around CO₂ Ownership
The standard does not require disclosure of:
- Who owns the CO₂ once injected
- Who owns future credits
- Who bears permanence risk if stored CO₂ migrates or fails
Landowners often carry the footprint without owning the value.
❌ Consent or Negotiation Standards
RP 1192 does not include:
- Best practices for landowner negotiation
- Consent thresholds
- Community engagement standards
- Dispute resolution frameworks
It governs pipe behavior — not power balance.
❌ Regulatory Shielding
While not a law, RP 1192 will likely be cited to claim:
“Industry best practices were followed.”
That protects operators institutionally — not landowners individually.
❌ ❌ API’s Real Landowner Issue ❌ ❌
RP 1192 responds to that resistance not by engaging landowners or strengthening market consent, but by reinforcing the institutional certainty needed to move projects forward anyway.
In doing so, it assumes compliance rather than earning it — a posture that may simplify permitting, but undermines both free-market principles and respect for private property.
At The End Of The Free Market’s Day…
It does not improve how landowners are treated.
Safety standards reduce operational uncertainty — they do not restore bargaining power, market choice, or property rights.
Landowners should understand that compliance with RP 1192 is not a substitute for consent, compensation, or long-term accountability.
API RP 1192 makes CO₂ pipelines easier to finance, permit, and defend.
It does not make them more legitimate in a free-market sense.
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Chuck Carbondale has worked at the intersection of communications and the energy industry for over 25 years. He has crafted messaging strategies for industry leaders, independent operators, and public utilities alike. Known for his sharp insight and unflinching analysis, he brings a seasoned, behind-the-scenes perspective to energy policy, market dynamics, and the evolving role of public perception. A staunch advocate for transparent communication and free market principles, Chuck’s work bridges boardrooms, work sites, and policy forums with equal fluency.
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