August 18th Railroad Commission Open MeetingThe Workover Blog | Aug 14, 2026

The Railroad Commission (RRC) permits, monitors, and enforces rules for all Texas oil and gas development. RRC decisions are critical to public health and climate emissions, yet the agency operates with little public accountability. For instance, the three elected Commissioners have deep financial ties to the industry they regulate, with two-thirds of their campaign contributions coming from oil and gas.

The RRC holds monthly open meetings. While challenging to follow, the open meetings are a valuable opportunity to get issues on the record and learn more about decisions that affect us and our communities.

The open meeting agenda for August 18th, 2026 at 9:30 AM is available.

Below are our agenda highlights with some additional notes and context.

Hearings Division

Oil & Gas

Item 8. ECTOR COUNTY. Application of Republic EES LLC to Renew its Permit to Operate a Commercial Stationary Treatment, Reclamation Plant, and Disposal Facility for Oil and Gas Waste.

  • Proposal for Decision (PFD), filed June 5, 2026. Examiners recommend approval of the Application to renew and amend the permit.
  • Protestants described the lack of clean water available in the region, “People have water wells down to 167 feet that used to be good but now have bad-tasting water.”
  • Even though there was flooding from one of the pits after a heavy rain in 2024, and a berm was washed out, RRC says that if the facility is operated as described in the draft permit, then this will not happen.
  • One of the neighboring landowners noted that people are getting sick from the winds that are blowing contaminants into their neighborhood. A girl that lives nearby “has mercury poisoning and is very sick.” The PFD notes “Protestants failed to raise air quality concerns within the Commission’s jurisdiction.”
  • This is an example of how the split jurisdiction between the Railroad Commission and the Texas Commission on Environmental Quality (TCEQ) fails to protect the health of the most vulnerable Texans. While the RRC is allowed to consider public comment and ultimately grant a facility permit to operate, there is no public comment process with the TCEQ before facility permits are granted. The TCEQ’s response time to investigate air quality complaints is notoriously slow, with the agency taking days or even months to investigate. Because of poor staffing at the agencies, lack of a robust air quality monitoring network enforcement of air pollution standards -if they exist- is not sufficient to protect human health.

Item 9. JEFFERSON COUNTY – Application of ExxonMobil Low Carbon Solutions Onshore Storage LLC for a Class VI Underground Injection Control Permit for Geologic Storage and Associated Injection of Anthropogenic Carbon Dioxide (CO2) for the Rose Carbon Capture and Storage Project.

  • Amended Proposal for Decision, filed July 31, 2026. Examiners recommend approval of the Application. The proposed injection period is 13 years.
  • No Harm Letter:
    • ExxonMobil submitted a letter from TCEQ indicating that the Class VI wells would not interfere with any TCEQ-regulated Class I injection wells (used for industrial and municipal hazardous and non-hazardous wastes) included a reference to “the extended area beyond the [area of review (AOR)] that is affected by increased reservoir pressures due to the CO2 injection to cover a 13-mile radius.” Protestants raised the concern that based on this letter, the CO2 plume might not stay within the company’s modeled AOR. The RRC PFD notes “The question of TCEQ’s intent in applying a 13-mile radius for its determination letter remains unanswered, as no representatives of TCEQ were available to testify.”
    • Instead of seeking out important information that may be relevant to the determination of whether the application will endanger groundwater, the RRC is content with having as little information as possible.
  • Pore Space Ownership: One of the protestants owns property within the AOR, but her pore space was not leased by ExxonMobil. ExxonMobil has only leased acreage for the first five years of injection. The PFD states “ExxonMobil asserts it can modify its injection strategy to prevent CO2 from being stored under any property where pore space rights have not been obtained.” Yet an expert witness for ExxonMobil admitted that “if the Commission issued a permit for the Rose Project that specifically required avoiding CO2 storage under the Cheek Community, the application would need to be revised.” RRC noted in the PFD “If, after five years, the extended pore space leases have not been obtained, ExxonMobil must control the plume to restrict CO2 storage to areas where it has pore space agreements.
  • Water protection: The PFD notes “Chapter 5 does not require that an aquifer must be protected simply because it is considered a [underground source of drinking water (USDW)] in a different region.”
    Importantly, some of the injection formations qualify as USDWs outside of the AOR.
    One fault was identified on the western side of the AOR, but RRC claims there is no risk of confinement loss related to this fault. An expert witness for the Cheek Community noted that ExxonMobil’s data provided in the application showed up to 35% uncertainty between predicted and actual results related to baseline fluid sampling, and that insufficient data was provided by ExxonMobil to confirm the quality of the confining zone and whether additional faults may exist. Importantly, “sands within the confining zone”…”were not visible in the 3D seismic data,” and “any of those unmapped features could provide a catastrophic leak-off zone.”
  • Emergency Response: The Cheek community expressed concern about human health and safety because the community only has a volunteer fire department. ExxonMobil said that it met with local first responders and provided them with CO2 monitors, and that in the event of an emergency, emergency services districts “can send text and phone notifications to residents and people within the geographic area.”

Item 10. CALDWELL COUNTY – Complaint of Hankey Family Limited Partnership that Viva Petrol LLP Does Not Have a Good Faith Claim to Operate. Proposal for Decision filed July 8, 2026. The Examiners recommend the Commission find Viva Petrol LLP does not have a good faith claim to operate the Lease, order any plugging extension cancelled, and order Viva Petrol LLP to plug and abandon the Wells. There were six wells on the lease.

Item 11. Commission Called Hearing at the Request of Waste Facilities, Inc. (Operator No. 900260) to Contest the Permit Conditions Included on its Facility Permit to Operate an On-Lease Commercial Solid Oil and Gas Waste Recycling Facility – Mobile Recycling Roadbase. Proposal for Decision filed March 24, 2026. Commission Shift wrote about this item in our post about the May 12, 2026 Open Meeting. Chairman Wright and Commissioner Craddick had moved to pass the agenda item to the next conference, though it was not discussed at the June 2026 Open meeting. No new information has been filed on this case since the May 2026 Open Meeting.

Item 13. GUADALUPE COUNTY – Application of Three J Energy, Inc. (Operator No. 857686) to Partially Supersede the Final Order Entered on May 17, 2023, in Oil and Gas Docket No. OG-23-00012755: Complaint of Roy J. and Sandra Lankford that Three J Energy, Inc. (Operator No. 857686) Does Not Have a Good Faith Claim to Operate. Proposal for decision filed June 29, 2026. The Examiners recommend denial of Three J’s application. The landowners are asking that the well be plugged. The operator has a new mineral lease for the well, and says it supports his good faith claim. The landowners says he signed the lease for the sole purpose of having the well plugged. The operator does not have financial assurance on file with the commission.

Item 15. MCMULLEN COUNTY – Complaint of McMullen Groundwater Conservation District Against ETC Texas P/L, Ltd Regarding Its Renewal Permit Issued for injection into reservoirs productive of oil, gas, or geothermal resources. There is no proposal for decision filed in this case as of August 11, 2026. McMullen GCD is requesting that “the ALJ issue an order establishing that (1) at hearing, ETC’s permit application should be reviewed as a new permit application, and (2) ETC bears the burden of proof at the hearing.” ETC requested that the ALJ convene a prehearing conference and give McMullen GCD a deadline for alleging any deficiencies in ETC’s permit renewal.

Items 18 to 23 involve several leases in Bastrop County between Trivista Operating and related mineral owners.

  • Proposal for Decision filed May 20, 2026.
  • Proposal for Decision filed June 22, 2026.
  • The Examiners recommend the Commission find Trivista Operating, LLC does not have a good faith claim to operate the Leases, order any plugging extensions canceled, and order Trivista Operating, LLC to plug and abandon the Wells within 60 days of the date a Final Order for these dockets becomes final. In some cases, the examiners are recommending Trivista otherwise bring all Commission Leases into compliance with the Statewide Rules, and that a good faith claim hold be placed on any Commission Form P-4 transfers for the subject Wells. Trivista’s leases have slowly been working their way through the RRC’s processes, and the RRC has found that they do not have a good faith claim to operate in several Bastrop County leases at the last two Open Meetings (May 12; June 2).

Items 24 – 26 are Motions for Rehearing filed by Trivista related to different leases in Bastrop County where the RRC determined Trivista did not have a good faith claim to operate at the May 12th open meeting. Trivista has since changed their attorney. On Apr 2, 2026, Trivista filed for Chapter 11 bankruptcy. On May 31, 2026, Trivista changed management, and they are arguing that their new management is actively working to bring the operator into compliance with all Commission requirements.

P-5 Denials

Items 27 – 37 are Motions for Rehearing for operators who were denied P-5 Organization Report Renewal, which is required to operate in the state of Texas. Cumulatively, these operators were flagged for 284 inactive wells out of compliance, with the largest offenders being CR2 Energy with 71 wells and Vaquero Operating with 124 wells.

Item 28. OG-26-00031255: For Denial of P-5 Organization Report Renewal for CR2 Energy, LLC (Operator No. 101608) Due to the Operator’s Failure to Bring Inactive Wells into Compliance with the Requirements of 16 TAC §3.15; Motion for Rehearing (71 wells). Court documents for CR2 Energy, LLC cited 71 inactive wells. Records today indicate the company still holds 20 ‘active’ wells. Reviewing production data for 2025, CR2 wells produced no oil and only 5,657 mcf of gas. Public records indicate this company is privately held, with production beginning in 2023. It took only 5 notices of violation and 2 enforcement actions for this young operation with very old wells to lose its P-5 license to operate.

Item 33. OG-26-00031274: For Denial of P-5 Organization Report Renewal for Vaquero Operating (Operator No. 882776) Due to the Operator’s Failure to Bring Inactive Wells into Compliance with the Requirements of 16 TAC §3.15; Motion for Rehearing (124 wells.) Vaquero has had a whopping 383 notices of violation since 2015, with 99 of those referred for legal enforcement, 11 severance/seal orders were issued and 4 wells were referred to state-managed plugging. 88 wells were non-compliant upon 315 reinspections, which indicates the company has done a poor job correcting problems. The most common violations were for inactive unplugged wells, unpermitted disposal of oil and gas wastes, and well signage.

Item 34. OG-26-00031669: For Denial of P-5 Organization Report Renewal for Lodestone Operating, Incorporated (Operator No. 100710) Due to the Operator’s Failure to Bring Inactive Wells into Compliance with the Requirements of 16 TAC §3.15; Motion for Rehearing (25 wells). Court documents for Lodestar indicate 25 inactive wells, and 32 violations since 2023 for signage and inactive-well issues, and 3 severance/seal orders.

Oil and Gas Consent Agenda

There are 5 flaring rule exception requests on the agenda from counties near Lubbock, in the Permian, and down to South Texas. Studies have shown increased odds of preterm birth for Hispanic mothers in the Eagle Ford Shale living next to high amounts of flaring.

There are 9 joint motions for rehearing by operators due to violations of inactive well rules, which could cause the operators to lose their ability to operate in Texas. RRC is considering denying motions for rehearing for operators holding 172 inactive wells, per court records. These wells will likely be orphaned if no operators take over the wells within one year, and the state will have to pay to plug the wells.

Rule 15 Inactive Well Items

34 companies are out of compliance with Rule 15 inactive well requirements. RRC can prevent them from operating in Texas until they comply, which could include plugging or removing surface equipment.

  • The operators may file a motion for rehearing to buy more time to come into compliance, but if they don’t come into compliance by the time the commissioners vote on their motion for rehearing, they may lose their ability to operate in Texas and the wells will be orphaned.
  • Court documents noted 475 inactive wells for these companies, however the inactive well report indicates a total of 1052 inactive wells associated with these companies. While many of these companies have, as one would expect, more active wells still producing oil and gas, there are a few companies on this list that one wonders how they have maintained their P-5 as long as they have and what story would come from a deeper examination.
  • The most concerning is AMRWR, LLC. AMRWR was cited in court filings with 34 inactive wells, however current inactive counts for the company are at 170, with over 163 of those as being inactive for greater than 5 years. They currently have 3 ‘active’ wells, however no reported oil or gas production for 2025. They’ve additionally received 65 notices of violation since June of 2025, with 24 of those for inactive unplugged wells, 13 referred to legal enforcement, and 1 referred for state-managed plugging.

Master Default Orders

RRC may enforce plugging requirements on dry and inactive wells in 35 default orders and another 12 agreed enforcement orders.

Administrative Matters

Financial Services

Item 878. Fiscal Year 2027 Operating Budget.

Item 879. Legislative Appropriations Request for Fiscal Year 2028-2029.

  • We are expecting the RRC to request funds for 86 Full Time-Equivalent (FTE) employees that will be needed to implement Senate Bill 1150 on inactive wells. The fiscal note prepared by the RRC during the 2025 legislative session indicated the agency would need 7 FTEs in 2026 and 2027 to develop the inactive wells inspection program and IT system -which the agency did not get appropriations for. The RRC estimated it will need 86 FTE’s per year, including 40 inspectors, to implement the new law once it goes into effect on September 1, 2027.

Oil and Gas Division

Items 881 and 882. Oil Field Cleanup Program Quarterly Status Report, Fiscal Year 2026, 2nd and 3rd quarters.

Commissioners

We typically don’t see specific items for presentation by individual Railroad Commissioners on the Open Meeting Agenda. This is a bit unusual.

Commissioner Christian

Item 883. Update on Outreach Activities Performed by the Office of Public Engagement.

Item 884. Proposal for Updated Public Engagement and Participation Policy. On June 17th, Commission Shift invited the Railroad Commission to attend an event we planned in Carrizo Springs for August 8, 2026. We received an email indicating that the request would need to be approved by leadership and that we would hear back in 5 – 7 business days. We did not hear back in that timeframe, and followed up with the RRC on July 6th. But they never responded to tell us whether they would attend or not.

At the April 14th Open Meeting, Commission Shift’s executive director Virginia Palacios gave Public Input, sharing that community members in East Texas asked the RRC to send someone to meet with their community and the RRC refused and directed the community to only communicate with the RRC’s attorneys. After Virginia’s Public Input, Commissioner Christian said that because some community members in a different community had been verbally aggressive at one point, that he didn’t want to send his staff to meet with the community requesting RRC staff to meet with them. This is a problem. It is not appropriate for state agencies overseeing a dangerous industry to refuse to meet with members of the public simply because members of the public expressed themselves.

Commission Shift has continued to advocate for Remote Public Input at Railroad Commission meetings to increase opportunities for impacted community members in distant parts of the state to address all three Railroad Commissioners at the same time. At previous Railroad Commission Open Meetings, Commissioner Christian has argued that Remote Public Input is not necessary because all three commissioners are available to speak with members of the public over the phone. The commissioners have touted the Office of Public Engagement as evidence that the agency is available to the public, yet the Commissioners are not allowing the Office of Public Engagement to meet public requests. Commission Shift requested an in-person meeting with Commissioner Christian’s office on May 29th, but no response was ever received. Our evidence shows that the Commissioners are choosing to avoid meeting with constituents that have problems the agency needs to solve.

Chairman Wright

Item 885. Election of the Chairman of the Railroad Commission.

  • Every year, the Railroad Commissioners elect a new Chairman. There are no commission rules or bylaws that define the Chairmanship or how it is voted on. The role of the Chairman is to preside over the Open Meetings. Typically, the Chairman of the Railroad Commission presents to members of the Texas Legislature in legislative committee hearings. Traditionally, the commissioner who will next be up for election is selected to be the Chairman of the Railroad Commission. Commissioner Wayne Christian will be up for election in the 2028 election cycle if he chooses to run again.

Public Input

The deadline to sign up to address the commission on an agenda item or during public input is noon Mon, August 17th. (Note: They don’t have to call on you if you’re commenting on an agenda item). Instructions for registering to give input can be found at the top of the RRC’s agenda for the open meeting.

People who want to speak on an item that is NOT on the agenda, must register to do so in the Public Input section. Note: you may not speak about an agenda item in the Public Input section.

RRC Open Meetings typically last less than half an hour.

Join us for a virtual debrief!

Commission Shift’s Virginia Palacios will be giving public input in person. Following the open meeting at 1 p.m. CST, we’ll also host a virtual debrief of the meeting’s agenda items and related topics. You can catch it streamed live on our Facebook page.

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