Client Alert: RRC Adopts New Pipeline Permit Rule

The Texas Railroad Commission (“RRC”) recently adopted amendments to the rule governing the pipeline permitting process.  The rule now requires a sworn statement and documentation as proof that a pipeline is a “common carrier” as part of the application for a T-4 Permit to Operate an Intrastate Pipeline.  Previously, an operator could merely “check the box” to indicate its status as a common carrier on the permit application.  This additional proof applies only to new pipeline permit applications; T-4 renewals are not required to provide the additional documentation and attestation.  The new version of the rule requires more information and effort from pipeline operators, but the adopted rule will, in practice, not have much impact.