Turning up the Heat at the Railroad Commission
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The summer heat arrived early this year, and we’re all watching the electric grid’s stability as we try to keep cool. After Winter Storm Uri, state leaders made some policy changes but have not made the large-scale reforms needed to make us feel more confident this summer.
New rules that require natural gas supply chain facilities to protect their equipment from extreme cold or hot weather are moving through a bureaucratic process but are not fully in place yet. Commission Shift has been following this weatherization rulemaking closely, and we will be advocating for common-sense safeguards that protect the people of Texas and the environment.
Last week the Railroad Commission of Texas, which oversees oil and gas drilling, held a hastily announced in-person only workshop in Austin on the weatherization rules. Announcing such an important public engagement opportunity right before the July 4 weekend and then holding the meeting the morning of July 5 is not helpful for the public. We continue to encourage the Railroad Commission to more robustly engage the public in their critically important decisions.
Last month, Commission Shift’s Executive Director, Virginia Palacios, provided public comments at a Railroad Commission meeting in Austin focused on carbon capture, utilization and storage (CCUS). CCUS is a relatively new technology 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 has applied for primary permitting and oversight authority from the U.S. Environmental Protection Agency over carbon dioxide injection wells in Texas. Recent well blowouts and the Railroad Commission’s ever-growing list of abandoned oil and gas wells show that the Railroad Commission 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 existing conflicts of interest will not improve the conditions of Texas' water, air, land or climate.
Meanwhile, Advocacy Director Tannya Benavides is making progress toward selecting a new Civic Engagement Organizer and a Community Organizer focused on language access to boost Commission Shift’s relationships on the ground in Texas. And Deputy Director Dr. Maria Reyes is diving deep into research and writing projects to make recommendations for improving the Railroad Commission.
We hope you stay cool this summer and that the electric grid holds strong. We will continue advocating with state leaders for the strongest possible protections to keep everyone thriving.
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Take Action: Protect the Grid from Extreme Weather
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The Railroad Commission is accepting public comment on a proposed new rule relating to weather emergency preparedness standards for the natural gas supply chain. The weatherization rule covers critical facilities that are also on the state’s Electricity Supply Chain Map, including natural gas wells and pipelines.
At Commission Shift, we encourage Texans to submit comments calling for stronger penalties that will encourage operators to weatherize their gas wells, pipelines, and related facilities.
The proposed rule’s draft penalty structure is not strong enough. For example, the proposed violation classification system would call for a maximum penalty of no more than $5,000 per violation even if an operator that produces the highest volumes of gas (> 5 million cubic feet per day) was deemed “reckless,” created a potential hazard to public health, safety, or economic welfare, and made no effort to remedy the violation. According to Gas Technology Institute, winter weatherization for gas wells can cost anywhere from $2,500 to just over $30,000. Penalties that don’t exceed $5,000 might lead operators to risk the violations rather than paying to weatherize their equipment, leaving Texans at risk of more widespread blackouts.
View the proposed rule (Chapter 3) and submit comments online by 5 P.M. Monday, August 15, 2022.
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Commission Shift produced a short video highlighting why we do what we do. Please watch, share, and support!
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National Association of Royalty Owners Convention
Dallas – July 13 - 16, 2022
Learn more
Commission Shift is a sponsor of this week's National Association of Royalty Owners (NARO) Texas and New Mexico Convention. We hear all the time from land and mineral owners concerned about inadequate oversight from the Railroad Commission, and we look forward to meeting more people and helping them get engaged.
RRC Regulatory Conference
Austin - August 8 - 9, 2022
Learn more
The Railroad Commission is hosting a conference offering instruction and details regarding its new critical infrastructure rule, upcoming weatherization standards, and pipeline safety, among other topics.
Texas Groundwater Summit
San Antonio - August 30 - September 1, 2022
Learn more
Commission Shift is a sponsor of the Texas Groundwater Summit - “the premier groundwater event in the state, bringing together a diverse group of groundwater professionals over three days to discuss emerging trends and new research.”
Texas Land and Mineral Owners Association
San Antonio - October 6, 2022
TLMA members can register here, and non-members can email info@tlma.org to learn more.
Commission Shift is a sponsor of the Texas Land and Mineral Owners Association’s Statewide Members Meeting. Early registration is available through Sep 23, 2022. The agenda includes speakers on topics like produced water and carbon sequestration.
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Commission Shift and 36 Texas-based organizations filed official comments with the Railroad Commission objecting to the agency’s request to oversee carbon dioxide injection wells. 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.
“Don’t hand the keys to someone who has proven they are an unsafe driver,” Commission Shift Executive Director Virginia Palacios said in a press release. “The Railroad Commission’s track record of inadequate oversight means that the U.S. EPA should remain in charge of carbon injection wells in Texas.”
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El Organizador Comunitario implementará estrategias de organización de bases en múltiples regiones de petróleo y gas en el estado de Texas, e identificar y construir relaciones con comunidades hispanohablantes afectadas por el desarrollo de petróleo y gas que han sufrido una carencia de accesibilidad lingüísticas. Esto incluirá la educación y la generación de apoyo público para poder responsabilizar a la Comisión de Ferrocarriles de Texas de su misión durante esta transición de energía en el estado.
Se busca alguien basado en una región de Texas que produce petróleo o gas natural como el esquisto Eagle Ford o Permian Basin. Se considerarán otras ubicaciones. El salario será entre $50,000 y $55,000 al año dependiendo de la experiencia. Habrá que viajar y tener un record limpio de manejar vehículos. Visite nuestra página web para mayor información y para solicitar.
Community Organizer: Implement grassroots organizing strategies in multiple oil and gas regions across the state of Texas and to identify and build relationships with Spanish-preferred communities affected by oil and gas development who need language accommodation from the Railroad Commission. This will include educating and building public support to hold the Railroad Commission of Texas accountable to its mission in a shifting energy landscape.
This position can be based anywhere in Texas, but preferably in an oil and gas producing region such as the Eagle Ford Shale or Permian Basin. The salary range is $50,000 - $55,000 depending on experience. Travel and clean driving record required. Full details and application instructions here. Vea en español.
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Welcome New Board Members
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Join us in welcoming long-time advocates John Beard, Jr. and Marisa Perales to the Commission Shift board of directors.
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John Beard, Jr. is the founder and CEO of the Port Arthur Community Action Network (PA-CAN), serving as an advocate focusing on environmental issues, social justice and community development in Port Arthur, Texas. He retired from ExxonMobil Corp. with over 38 years of service in petrochemical production, maintenance services and emergency management. He is a former City Councilman and Mayor Pro Tem. During his twelve years on city council, he helped guide the city’s recovery from Hurricanes Rita, Ike, Gilbert, Humberto, and most recently Harvey and Imelda. He has spent the past 17 years as a liaison to the city and community, helping educate about flood risks and the causes of disparate impacts. He is an active member of the Texas Water Development Board’s Regional Flood Planning Group for Region 5, a member of the board of directors of Big Thicket Association and chair of the City of Port Arthur’s Zoning Board of Adjustments.
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Marisa Perales is a partner in Perales, Allmon & Ice, P.C., a small environmental law firm that advocates against polluters and in favor of the public's interest throughout Texas. The firm addresses various environmental issues that arise in Texas, including municipal, hazardous, and radioactive waste storage and disposal; water quality and air pollution; endangered species protection; and incompatible land uses. She also serves on the board of Clean Water Action and as board president of Texas Campaign for the Environment Fund. Believing that environmental advocacy must lead with equity and justice, Ms. Perales was a founding member of the Undoing Racism Austin coalition and is currently a member of Communities of Color United for Racial Justice (CCU), a grassroots coalition of people of color organizations and individuals working for racial equity and social justice.
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- Virginia Palacios (Commission Shift) co-wrote an essay with Megan Milliken Biven (True Transition) and Ted Boettner (Ohio River Valley Institute) in the American Prospect arguing that the fossil fuel industry should pay for its own cleanup.
- Texas Monthly published an important feature on a leaking offshore oil well in state waters, showing the need for stronger Railroad Commission policies for offshore abandoned wells.
- The Houston Chronicle editorial board agreed with Commission Shift’s position that the Railroad Commission should not be in charge of regulating carbon capture and sequestration.
Find more coverage on our news page.
P.S. Be sure to follow Commission Shift on Facebook, Twitter, Instagram, and LinkedIn
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Commission Shift
212 Flores Avenue
Laredo, TX 78040
United States
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