On January 2, 2025, the Railroad Commission of Texas released notice to all pipeline operators in Texas that additional updates to the T-4 Permitting process have been made and are effective immediately.

The updates are as follows:

• Form C-LTR POPS Cover Letter: The December 2024 version is the most recent and is required.

• T-4B Pipeline Transfer Certification: The August 2024 version is the most recent and is required.

• A Guide to Shapefile Submissions: Version 2024.12.12 is the most recent.

• Amendments to 16 TAC 3.70 have been adopted as of December 9, 2024. The adoption notes can be found here: https://www.sos.state.tx.us/texreg/archive/December62024/Adopted%20Rules/16.ECONOMIC%20REGULATION.html#123.

• Per 16 TAC 3.70(r)(1), operators with active intrastate natural gas gathering pipelines must amend their T-4 permits by March 31, 2025, to include the required attributes and indicate the appropriate Type of A, B, C, or R. Failure to do so could result in a $5,000 penalty per permit in accordance with 16 TAC 3.70(p).
• Per 16 TAC 3.70(r)(2), 2025 renewal applications submitted for all intrastate gas permits must include an attestation statement regarding the natural gas gathering requirements.

• To assist operators with the attestation statement requirement, a sample Form C-LTR POPS Cover Letter has been pre-filled with statements in the Additional Information section on page 3 of the form. Operators should delete the statements that do not apply. The sample 2025 Renewal C-LTR is available for download in the Other Samples section on this page: https://www.rrc.texas.gov/pipeline-safety/pipeline-safety-forms/#PipelinePermitting.

Updated resources can be found on our Permitting & Mapping web page here: https://www.rrc.texas.gov/pipeline-safety/permitting-and-mapping/.

CALL PAPS TODAY AT 281.379.1130 OR VIA EMAIL AT [email protected] TO LEARN HOW PAPS CAN HELP!