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Public Participation

Inclusive decision making is one of Commission Shift’s core values. We believe that oil and gas workers, farmers and ranchers, neighbors of oil and gas development, students of Texas’ public schools, energy consumers, and the many others that are affected by the oil and gas industry in Texas deserve stability, safety, clean air, and clean water.

Our state can achieve better results in rulemakings, strategic plans, permit proceedings, and more when the public is meaningfully engaged, authentically listened to, and when their needs are incorporated into decisions.

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Monitoring and Enforcement (Closed for comment)

The Railroad Commission approved the final version of its Monitoring and Enforcement Plan for FY 2023 at its June 7th open meeting. The public comments that were submitted by April 29, 2022 are available on the Railroad Commission's Enforcement Activities webpage.

We commented on the plan last year, and we documented how RRC did not fulfill its statutory requirements for what should be included in the plan. Read more about the last plan (FY2022) here.

For a quick overview of what was in the FY 2023 draft plan (17 minutes), you may view a recording of our Community Conversation from March 31, 2022.

If you or anyone you know may need language accommodation in Spanish, please share the following:

Dile a la RRC lo que piensas a su Plan de Monitoreo y Cumplimiento de la División de Petróleo y Gas para el Año Fiscal 2023.

 

Carbon Capture, Utilization, and Storage

Carbon capture, utilization, and storage (CCUS) are relatively new technologies designed to prevent greenhouse gas emissions from warming our climate. Communities from the Permian to Gulf Coast face uncertain risks posed by these new technologies -especially when faced with poor oversight. The Railroad Commission of Texas is planning to apply for primary permitting and oversight authority from the U.S. Environmental Protection Agency (EPA) over carbon dioxide injection wells in Texas. The Railroad Commission of Texas has a poor track record protecting groundwater aquifers, preventing leaks on oil and gas infrastructure, and enforcing its own rules. Adding more responsibilities to an already overburdened agency with with existing conflicts of interest will not improve the conditions of Texas' water, air, land or climate.

Railroad Commission Proposed Rule Amendments (Closed for comment)

The Railroad Commission of Texas accepted comments through July 1, 2022 on its proposed amendments to its Chapter 5 rules on carbon dioxide storage and injection and its pre-application to the EPA to be the state's sole authority to permit and regulate Class VI carbon dioxide injection wells.

Commission Shift and 36 Texas-based organizations filed official comments with the Railroad Commission objecting to the agency’s pre-application for Class VI primacy. New carbon dioxide injection wells would be held to the RRC’s same financial assurance and inactive well plugging extension rules that have allowed nearly 8,000 orphaned wells and 140,000 inactive unplugged wells to accumulate across the state. Out of the inactive wells that operators are still on the hook for, over 17,000 are more than 20 years old. This pattern of behavior and poor oversight disqualifies the Railroad Commission from overseeing such a complex and significant technology.

The commission hosted a virtual public hearing on the proposed rules on June 14, 2022, at 9:30 a.m. The hearing lasted approximately half an hour, and three individuals gave public comment, including Commission Shift's Executive Director, Virginia Palacios.  Click here to read Commission Shift's comments at the virtual public hearing on June 14, 2022.

White House Council on Environmental Quality Guidance (Closed for comment)

Commission Shift joined 19 other groups to send official comments to the White House Council on Environmental Quality on the proposed “Carbon Capture, Utilization, and Sequestration (CCUS) Guidance.” The comment deadline was April 17, 2022.

These organizations represent Texas communities that would be the most impacted by onshore and offshore carbon storage, carbon dioxide pipeline expansion, industrial chemical processing for CCUS purposes, and utilization of carbon dioxide for enhanced oil recovery (EOR). This broad-based set of Texas advocacy groups and experts is sending the White House a clear message about what we want to see in the final guidance.

Last updated: July 13, 2022.

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