Recap: 2026 Railroad Commission Regulatory ConferenceThe Workover Blog | Jul 28, 2026

The July 13-15 Railroad Commission of Texas training event provided insight on navigating Texas energy regulations, procedures and processes. Read on for our notes and highlights from the conference.

Fireside Chat with RRC Commissioner and Chairman Jim Wright & Rep. Drew Darby

On Orphaned and inactive wells: SB1150

• Repeated calls from Commissioner Wright and Rep. Darby for companies to give feedback on SB 1150 inactive wells bill.
• Rep. Darby emphasized that a lot of landowners and environmentalists care about these wells, and the legislature is trying to address a longstanding problem.
• They want feedback from operators on the rulemaking, and they will have the next legislative session to fix the rule if they need to. Rep. Darby emphasized: “No one wants wells perpetually unplugged”; “We have to make progress, we cannot leave this unattended”; “Work together to come up with rules that make sense”

On Orphaned and inactive wells: bonding amounts

• Commissioner Wright: Need to remember why bond rates are set where they are. Set to encourage development. (He seems to be advocating for low bonding amounts here).
• Once a well is plugged, the resources are not recoverable.
• Rep Darby: Passing wells to an entity that can’t reactivate or plug the wells is passing the liability on to taxpayers. Operators can’t just have an affidavit that the well is economically viable without a plan to reactivate it.
• They both spent some time emphasizing the importance of the compliance plans.

On Produced Water in Texas

• About 15 years ago there were a lot of earthquakes in Azle, TX (due to pressurized injection). That’s when the state decided to find the TexNet seismic monitoring system.
• “We now have enough science to know we’re running out of places to put it” (produced water)
• Rep. Darby acknowledges we’re taking produced water from Louisiana and New Mexico
• Without a place to put the water, oil and gas will go away, so we need to treat produced water for reuse
• Texas Pacific Land Corporation is spraying produced water on crops and getting twice the yield. Two plots are testing crop irrigation on alfalfa; better than natural rainfall
• Commissioner Wright: This can “lessen the drought”
• Darby talks about how they made sure that the company that aggregates the produced water from multiple sources and treats it gets to own the produced water, and that all surface owners’ claims of ownership over the produced water are cut off.
• Economics aren’t there for produced water treatment, it’s still cheaper to inject it.
• Rep. Darby: “We have to create economic incentives to incentivize industry and folks to spend that extra dollar to treat that water.”
• Rep. Darby: We don’t bill for the water itself, only the treatment and distribution. He advocates for billing for scarcity of the resource.

On Carbon Capture, Use and Storage in Texas

• A lot of talk on reducing companies’ costs.

• “We need more projects”

• *Note: Some industry experts at the conference are saying CCS development is slowing down because of the uncertainty around whether taxpayer-funded government subsidies (i.e. the 45Q tax credit) will go away.

• Darby said he focused on nuisance and liability; the purpose is to limit litigation expenses for operators. Left on the table & will be addressed this session.

• • • Darby noted “If they’re operating according to the permit that you give them, then from a liability standpoint, they’re only liable for those consequential damages arising out of failing to adhere to those rules and not some third party nuisance value that says their operation is a nuisance and therefore it needs to be stopped and I’ve been damaged by it.”
    • (Note: so if the rules for permitting are weak, and someone is harmed from a facility, yet the operator is in compliance, then under Darby’s proposal the person harmed would not be able to file a nuisance claim.)

• Only getting 7 – 10% of what’s in tight rock.
• (It’s not clear that they know what the difference is between enhanced oil recovery (EOR) and Class VI injection (storage) – I wonder if they’re conflating it intentionally or not.)

Commissioner Wright, Representative Cody Harris, & TXOGA President Todd Staples

• Todd Staples emphasized how important it was for the audience to vote.
  • Texas is the 8th largest economy in the world because of oil and gas
  • Texas collected $27 Billion in state and local taxes last year from oil and gas, which exceeds the general tax revenue of 34 states.
  • He said that there are environmental groups out there spreading misinformation, but didn’t say what information they were spreading or name any groups.
• Commissioner Wright notes that we’re getting less rainfall, and asks how we can take on AI data centers if people don’t have water.
• Rep. Harris notes the Texas Water Development Board’s water plan, and additional funding for it.
• On CCS, Staples noted that CCS is a trillion dollar industry worldwide.
• Rep. Harris notes that CCS is not on the radar for most East Texans.
  • They see unplugged wells as a problem they’re being saddled with. RRC is doing a good job going after the well plugging funds, and there is a growing need.
• Staples notes it is “each company’s responsibility to take care of their inventory”…”some companies shirk their responsibility” and he mentions that if a well has a future economic use, then it would be wasteful to plug it.
  • (Note: only 15% of wells that are inactive 5 years or longer ever get reactivated.)
• Wright mentions that there are new technologies for repurposing wells, including a lithium company that wanted to be able to use some abandoned wells for lithium production.
• On AI Data Centers and Electricity
  • We have to keep up and upgrade our infrastructure.
  • Landowners don’t like the large right of way (ROW) for the 765 kilowatt line, but if we didn’t have that, then we would need a ROW 3x as wide for three lower capacity lines.
  • Closed loop cooling systems for data centers may not be the best.

PHMSA Headquarters update, from Paul Roberti, PHMSA Administrator

On Carbon dioxide

• • They have outstanding mandates from congress on CO2 pipeline rules.
  • If congress provides a mandate, he’s going to get the mandates done
  • Leak detection: Pulled back because scope was too broad. Going to get that done too.
  • Industry consensus-based standards, says those are important
  • Expected that freed-up money goes back to work to advance safety.

• Audience question for Paul Roberti: How will PHMSA address the risks posed by carbon dioxide (CO2) pipelines without a federal rule that considers the unique characteristics of CO2?

• • I don’t know that anyone’s ever died from a CO2 pipeline… I know we had a lot of hospitalizations in Satartia plus a $2.8 MM fine from PHMSA
  • Had the operator done what was plainly stated in code, that incident would not have happened – covers supercritical CO2
  • Part 195 fully captures right now.
  • Says we don’t need to update the code because something bad happened, need to enforce on the operator
  • Gaseous CO2 – there’s a congressional mandate, and they’ll get to that. Will likely look to API standards.