Fall is shaping up as a critical time for our industry, where regulatory policy-making is concerned. Companies are advised to be ready to express themselves on proposed changes when the opportunities arise.
As summer rolls on and the Legislature reconvenes for transportation issues, planning is underway in Austin for a series of regulatory and legislative initiatives. All of these are expected to have an impact on how our industry does its business.
At the Railroad Commission, Statewide Rule (SWR) 13 implementation planning is well underway for the January 1, 2014, effective date. Industry is being invited to attend a series of meetings with agency staff to discuss how this new rule will work and the impact on operators, both in the field as well as in permitting and filing. You might want to have some of your staff review the Powerpoint presentations that are on the Commission webpage to make sure they get any questions they may have answered by the agency before the rule is put in place.
Also, Statewide Rules 9/46, Injection rules, are expected to be formally opened for updating before summer is over. It is estimated that almost 99 percent of oil field waste is produced water, and virtually all of it is disposed through injection. That’s comes to approximately 7 billion bbls of produced water going down disposal wells in Texas this year. So, all operators will want to pay very close attention to any revisions of this critical rule. I think we can all expect “robust” comments from industry, similar to the intense industry scrutiny placed on SWR 13 Completion Requirements when it was first published in the fall of 2012.
Railroad Commission staff has agreed to come to the Permian Basin to present both SWR 13 and 9/46 to our members. They will be here on September 4th. PBPA will host additional informational meetings this fall, so please make plans to attend one of these sessions.
At the Legislature, discussions are under way regarding what interim studies should be held in the key committees. If industry has opinions, now is the time to talk with the committee chairmen, members, and their staffers. Some of the topics will not be a surprise. Issues like water will continue to dominate the legislative review. However, with the RRC up for Sunset in four years, any interaction between industry and regulator and the public is fair game, including enforcement, inspections, agency budget, and the new Information Technology initiative at the RRC.
Summer is long in Texas, but this year the regulatory and legislative calendars will be even longer.