As most of you know, I had the incredible honor of serving as your Texas Railroad Commissioner from 2011 through 2017. After leaving office, I had a strong desire to continue the vital work performed at the Commission and maintain involvement in the important issues that impact our state. I founded 98th Meridian Foundation, a nonprofit organization, which aims to study, educate and initiate high-level dialogue around issues in order to bring forth reasonable solutions. These issues all seemed to fall within three general areas: water, land and energy. They are of great importance to all Texans, our economy and, indeed, life itself.
Today, I’m excited to share with you the first of many white papers: Texas Disposal and Injection Well Regulation.
Produced water management is one of the biggest issues facing the oil and gas industry today, with disposal through injection being the most utilized method currently. As a former regulator, I wanted to start a serious dialogue around the regulations and permitting process in order to better account for risk profiles associated with certain higher-volume disposal wells. I know some of the recommendations will be controversial, and I welcome productive discussions around these ideas.
In the paper, I propose bifurcating rules to create two different levels of well categorization: high-volume/high-pressure wells, and low-volume/low-pressure wells. To greater account for risk profiles of each well, all high-volume disposal wells (HVDWs) should be subject to heightened standards from a permitting and regulatory perspective.
Additionally, the paper suggests increased beneficial reuse of produced water in lieu of disposing the fluid and removing it from the hydraulic cycle. Beneficial reuses of produced water include, but are not limited to: use in hydraulic fracturing fluid and other wellbore uses; mining; power generation, such as cooling ponds; irrigation of nonedible crops and large-scale watering operations; irrigation of consumable crops; and potentially even drinking water.