Proposed Amendments to 16 TAC §3.8 and various other rules in Chapter 3 and proposed new rules and amendments in 16 TAC Chapter 4
October 15, 2024
Rules Coordinator
Railroad Commission of Texas
Submitted via email
RE: Proposed Amendments to 16 TAC §3.8 and various other rules in Chapter 3 and proposed new rules and amendments in 16 TAC Chapter 4
The Permian Basin Petroleum Association (“PBPA”) greatly appreciates the opportunity to provide feedback on these proposed rules and 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 world-wide operations. We firmly believe that Texas, the United States, and our allies benefit from a vibrant and diverse oil and gas sector. To maintain these benefits, we are committed to continuing the development of these resources for generations to come.
Regarding this proposed rule our members recognize the importance of modernizing certain provisions of Chapter 3, Rule 8 (“Rule 8”) as well as complying with legislative mandates in order to establish efficient, consistent, and orderly permitting for commercial disposal facilities. Our members would like to ensure that these efforts are consistent with the goals of the industry, the Commission, the Legislature and the public at large to ensure the safe and responsible development of the natural resources in the Permian Basin.
To be clear, our members support these efforts and encourage the Commission and industry to continue working together to modernize waste practices. PBPA does not believe that environmental protection and natural resource development are mutually exclusive. Texas can, and has long been, a leader in both.
PBPA agrees with the Railroad Commission’s characterization of this rulemaking one year ago, that this is a major overhaul for water protection and oil and gas waste management rules. In that description the Commission noted that “for the first time in nearly 40 years, the Railroad Commission’s Statewide Rule 8 will undergo a substantial overhaul to better reflect modern waste management practices and recent advancements in production method.
This proposed rulemaking is a....