Texas Railroad Commission Unveils Oilfield Relief Initiative

Texas Railroad Commissioner Christi Craddick on Aug. 9 announced details of a new oilfield relief initiative for the state.

The first rule amendments for the initiative were released during the Commissioners’ open conference. The initiative improves efficiencies for the state’s energy regulatory body, as well as oil and gas producers working to sustain business operations during the current downturn in the energy sector, according to the Railroad Commission of Texas (RRC).

The RRC said that the initiative will reduce the regulatory administrative burden on industry while ensuring the RRC continues to protect the public and environment. 

“This initiative is part of my ongoing efforts to adjust our processes and put in place common sense practices that achieve greater effectiveness in regulating energy the way it is produced today,” Craddick said in an Aug. 9 statement. “During my time at the Commission, these efforts have not only included a reevaluation of our methods and rules, but also an overhaul of our IT programs.

Craddick added that the initiative calls for a more thorough review in a time of industry slow-down to save time and money for the state and those doing business at the agency.

“These initial ideas brought forth in the initiative will save extensive time for our staff and tens of millions of dollars for oil and gas operators,” Craddick said. “This initiative serves as phase one of a long-term effort to streamline our operations that our executive director and staff will continue to carry out.”

The initiative results from a comprehensive review of the RRC’s regulatory processes, and seeks “to avoid weakening public and environmental protections, correlative rights, or measures designed to prevent the waste of resources,” the RRC said.

Judy Stark, Panhandle Producers and Royalty Owners Association (PPROA) executive vice president, applauded the initiative.

“With the current industry downturn, at stake is the survival of the state’s small producers and the oil industry’s many marginal wells, which make up 85 percent of total U.S. oil wells and 18 percent of the nation’s total oil output,” Stark said in a statement. “During this critical time, Commissioner Craddick’s initiative will provide relief to Texas’ independent producers, the backbone of both our state and nation’s oil industry. For that, PPROA’s members are truly grateful.”

The initiative includes the following items for implementation:

• Identify agency reports and filings that can be reduced or eliminated, saving operating costs without affecting public or environmental safety.
  • Amend Statewide Rule (SWR) 28 to modify gas well deliverability reporting requirements.
  • Reduce the need for G-10 (Gas Well Status Report) filings except for surface commingled production.
• Allow a calculated well shut-in pressure to be provided when filing Form G-10 for gas wells to reduce regulatory administrative burden.
• Amend production requirements for marginal and stripper wells to reduce regulatory administrative burdens. 
  • Revise “Active Oil Well” definition from 10 barrels of oil (BO) per month for three consecutive months to five BO per month for three consecutive months or any reported production in each month for a consecutive 12-month period
    (SWR 15).
  • Revise “Active Gas Well” definition from 100 mcfg per month to 50 mcfg per month or any reported production in each month for a consecutive 12-month period
    (SWR 15).
• Implement a revised internal inspection priority system so RRC inspectors prioritize drilling rig inspections and hydraulic fracture treatments in sensitive areas, such as cities or wetlands, without affecting other inspections.
• The agency’s new online completion program calculates the depth of cement behind casing (cement tops) using washout factors that have been used by the RRC for decades. A review of these washout factors should be conducted to determine whether different washout factors should be used in certain areas of the state to calculate cement tops. This will expedite the process of verifying compliance with these rules for both operators and the agency without compromising well integrity.
• The Groundwater Advisory Unit (GAU) will identify counties or portions of counties in which the usable quality water protection depth is constant. Those areas will be eligible for area-wide recommendations for meeting surface casing requirements, streamlining regulatory requirements for industry. 
• Issue guidance for implementation of the Texas Environmental, Health & Safety Audit Privilege Act, permitting operators of new property to identify and remedy violations resulting previous to their ownership. This guidance ensures compliance without punishing an operator not responsible for the cause of the violation.
• Conduct an extensive review of all RRC forms required for application and reporting purposes and determine whether data collected is currently used or no longer necessary. Eliminate forms no longer useful to the RRC’s regulatory functions to reduce regulatory administrative burden on staff and industry.
• Simplify the complete duplication of a drilling permit application with a sworn statement of no changes to the original application. The operator would then pay the fee for reissuance of the permit, speeding up the review process and reducing regulatory administrative burden for both the agency and industry. —JD

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