Proposed amendments to 16 TAC §3.70 and various rules in Chapter 8
October 15, 2024
Rules Coordinator
Railroad Commission of Texas
Submitted via email
RE: Proposed amendments to 16 TAC §3.70 and various rules in Chapter 8
The Permian Basin Petroleum Association “PBPA” greatly appreciates the opportunity to provide feedback on these proposed rules as thanks the Commissioners and staff for their work throughout this important process. As you know, our membership includes the smallest exploration, service and support companies as well as some of the largest oil and natural gas companies with worldwide operations. We firmly believe that Texas, the United States, and our allies benefit from a vibrant and diverse oil and gas sector and are committed to continuing the development of these resources for generations to come.
With regard to the proposed amendments within Chapter 3, PBPA has solicited and received the following member feedback for the Commission to consider. Broadly, our membership generally supports the rule which incorporates recent federal rulemakings by the Pipeline and Hazardous Materials Safety Administration (“PHMSA”) but do have concerns about a few key provisions.
Several members note that one proposed change would add a requirement for adding Type R lines to submit shapefiles with our T-4 permit requests. This goes beyond PHMSA’s requirements and operators have noted they may utilize other methods and may not have GIS centerline data for these lines and would suggest this requirement not be included in the final rule.
In Figure 2: 16 TAC §8.101(b)(2) it is recommended that the title “Liquid Pipelines” be changed to “Liquid Pipelines Subject to 49 CFR Part 195 Requirements.” The Texas Railroad Commission generally requires that interstate, rural, non-regulated systems be permitted. Non-regulated systems that are permitted should not be subject to Pipeline Integrity Assessment and Management Plans in 16 TAC §8.101. This is stated in proposed rule language and for consistency should also be clearly referenced in the title of Figure 2.
Another concern is...