Energy & Critical Minerals · Regulatory

Railroad Commission practice,
permits to hearings.

Permit applications and protests, Rule 37 and 38 exceptions, Rule 82 brine production permits, Rule 46 geothermal injection permits, operator compliance, and hearings before the Commission and SOAH — with the title work run alongside.

The Railroad Commission of Texas decides who gets to drill, where, how densely, and under what conditions — and, under 2023 legislation and its 2025 brine rule, its role now extends to closed-loop geothermal wells and brine production. We represent operators, applicants, and protestants before the Commission and in the district-court proceedings that sometimes follow.

What we do.

01

Permit applications

Drilling permits (Form W-1), Rule 82 brine production permits, Rule 46 geothermal and geopressured injection permits (Form GT-5), disposal permits, and the supporting plats, surveys, and organizational filings.

02

Protests & hearings

Prosecuting and defending protests to drilling, spacing, density, pooling, and injection applications before the RRC Hearings Division and SOAH — standing, scope, the merits, exceptions, and judicial review.

03

Rule 46 / Rule 82 classification

Advising on which program governs a project that recovers minerals from geothermal or produced fluid, and preparing the corresponding filings.

04

Rule 37 & Rule 38 exceptions

Spacing and density exception applications and protests, including the geological and engineering case and expert coordination.

05

Brine, geothermal & injection permitting

Rule 82 (16 TAC §3.82) brine production permits and Class V spent-brine return wells; Rule 46 (16 TAC §3.46) injection permits for geothermal and geopressured energy-storage wells; Class II disposal and enhanced-recovery permits; and area-of-review work.

06

Operator compliance

P-5 organization reports, financial assurance, inactive-well and plugging obligations, severance and seal orders, and enforcement responses.

07

Title & possession disputes

Coordination between Commission proceedings and the district-court title actions that determine the right to drill — the Commission decides permits, not title, and the two tracks must be run together.

08

Field rules & pooling

Field rule applications and amendments, unit and pooling designations, and MIPA-related proceedings.

09

Appeals

Motions for rehearing and judicial review of Commission orders in Travis County district court.

Contested dockets.

The Commission's statutory charge is the prevention of waste and the conservation and orderly development of the State's resources (Natural Resources Code §§85.201–.202), and a well-prepared application is framed with that charge in view. In a protested docket, four questions usually organize the work:

  • Standing. An "affected person" must show concrete injury; Rule 46(c)(5)(B) excludes injury suffered merely as a competitor, and Rule 82 requires concrete or actual injury or a substantial risk of it. The Commissioners decide the threshold on the full record (NGL Water Solutions Eagle Ford, Tex. App.—Austin 2019; Railroad Commission v. Apache, Tex. App.—Amarillo 2023).
  • Scope. Each program has its own permit findings — Rule 46's concern protection of fresh water and non-endangerment of oil, gas, and geothermal resources — and issues that belong to another program are addressed in that program.
  • Permits and title. The Commission has no power to determine property rights and its permits confer none (Magnolia Petroleum, Tex. 1943; Gregg v. Delhi-Taylor, Tex. 1961); the good-faith-claim standard exists so that contested ownership does not stall permitting. Title questions are resolved in the courthouse, and because we handle title and Commission work in the same office, the two proceedings are coordinated rather than run by two firms learning the same file.
  • Schedule. Continuances, abatement, and judicial review each carry their own rules — judicial review of a granted permit, for example, does not of itself suspend the decision (Gov't Code §2001.176(b)(3)) — and we advise clients on the operational consequences of each before it arises.

New regimes, first permits.

The brine production rule (Statewide Rule 82, 16 TAC §3.82, effective February 2025) and the Commission's expanded geothermal program are new enough that the first permits and dockets are shaping how the geothermal–brine interface will be regulated in the East Texas Smackover. Applicants benefit from counsel who has read the adoption order and the comment record, understands the Rule 46 / Rule 82 purpose test and the pending EPA Class V primacy question, and can anticipate staff's classification questions rather than react to them.

Common questions.

What happens when a drilling permit is protested?

The Commission sets the matter for hearing before its Hearings Division (or, in some cases, SOAH). Both sides exchange exhibits and testimony, the examiner hears the case, and a proposal for decision goes to the Commissioners. We handle both sides — prosecuting protests for offset operators and mineral owners, and defending applications for operators — and much of the value is in the pre-hearing work: the exhibit set, the expert testimony, and the settlement conversation the hearing date makes possible.

What is a Rule 37 exception, and when do you need one?

Statewide Rule 37 sets minimum spacing between wells and from lease and unit lines. A well that cannot meet those distances needs an exception, granted to prevent waste or protect correlative rights, and offset owners are entitled to notice and can protest. Rule 38 governs well density within a proration unit and has its own exception process. We prepare exception applications and the supporting geological and engineering case, and we protest them when a client's correlative rights are at stake.

Do you handle brine and injection permits as well as oil and gas?

Yes. Brine production permits under Statewide Rule 82 (16 TAC §3.82), Class V spent-brine return wells (with EPA coordination while the Commission's Class V primacy for brine is pending), Rule 46 (16 TAC §3.46) injection permits for geothermal and geopressured wells, Class II disposal and enhanced-recovery permits, and closed-loop geothermal wells under 16 TAC Chapter 6 are all Commission matters we handle, as is the threshold question of which program a mineral-recovering geothermal project falls under. More on brine permitting · more on geothermal.

Where do RRC hearings take place, and do we need Austin counsel?

Hearings are conducted in Austin, increasingly by videoconference. Our office is in Flower Mound in the Dallas–Fort Worth area; we appear in Austin as needed and there is no requirement for locally based counsel. What matters is knowing the Commission's rules and its examiners, which we do.

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