(817) 370-0612

Texas Railroad Commission (TRRC) Filing & Oil and Gas Regulatory Compliance

Quick answer: Valor can prepare and file Texas Railroad Commission (TRRC) paperwork for oil and gas operators — drilling permits, completion reports, P-5 organization reports, monthly production reports, injection and disposal permits, and hearing applications with expert testimony — and can handle compliance with Oklahoma’s OCC, New Mexico’s OCD, North Dakota’s DMR, Louisiana, Colorado’s ECMC, and the BLM. Valor’s regulatory specialists can give expert testimony at Rule 37 and Rule 38 hearings.
Talk to Valor about regulatory filings (817) 370-0612

A short conversation about your wells, states, and upcoming filings. Valor typically follows up with a proposal for how the work would flow.

  • Expert testimonyRule 37 & 38 hearings
  • SOC-certifiedcontrols
  • Inc. 50002021–2025
  • BBB A+rating

What Is the Texas Railroad Commission (TRRC)?

The Texas Railroad Commission (RRC, often written TRRC) is the state agency that regulates oil and gas in Texas: drilling permits, well completions, monthly production reports, P-5 operator registration, pipeline safety, and well plugging. Despite its name, it no longer regulates railroads. Every Texas operator files with the RRC, and Valor can prepare and submit those filings as part of its regulatory compliance service.

Regulators Valor Files With

Oil and gas regulators Valor can file with
JurisdictionRegulator
TexasRailroad Commission of Texas (RRC)
OklahomaOklahoma Corporation Commission (OCC)
New MexicoOil Conservation Division (OCD)
North DakotaDepartment of Mineral Resources (DMR)
LouisianaOffice of Conservation
ColoradoEnergy & Carbon Management Commission (ECMC)
Federal landsBureau of Land Management (BLM)

A Compliance Calendar and an Audit Trail

Valor typically runs a compliance calendar that tracks each operator’s annual, quarterly, and monthly filings, because a missed filing can trigger fines, suspensions, and operator-of-record holds. Each filing is typically logged with its submission date, supporting documentation, and confirmation, which can support external audits and capital-partner due diligence. For pooling, increased-density, and spacing matters, including OCC pooling notices, Valor can coordinate with your regulatory counsel.

Hand off your regulatory filings

Tell us your states, well count, and what is coming due, and we can talk through how Valor would run it.

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Texas Railroad Commission Hearings, Letters of Application & Expert Testimony

Valor can file letters of application, prepare exhibits, and give expert testimony before the Railroad Commission of Texas for hearings including:

  • Field Rules: Adoption of temporary field rules, permanent field rules, and amendment of existing field rules
  • Statewide Rule 10: Downhole commingling applications
  • Special Allowable or MER Assignment: Maximum efficient rate determinations
  • Net Gas-Oil Ratio: Gas-oil ratio establishment and modifications
  • Statewide Rule 32 Hearings: Permanent and emergency flaring exceptions
  • Statewide Rule 37 Hearings: Spacing exceptions
  • Statewide Rule 38 Hearings: Density exceptions
  • Plugging Hearings: Plugging orders and rescission of plugging orders
  • Proration/Allowable Hearings: Production allocation determinations
  • Unitization Hearings: Unit formation and secondary recovery
  • Consolidation: Fields or reservoir consolidation
  • Flaring Applications: Gas flaring and venting permits

Railroad Commission Form Filing Services

Valor can file the Railroad Commission forms operators typically need to secure oil and gas allowable assignments:

  • Form W-1 and Plat: Drafting of uncertified plats and filing applications for permits not requiring certified plats
  • Expedited Drilling Permits: Expedited filing for urgent drilling applications
  • Surface Casing Recommendations: Expedited surface casing requests
  • Form W-2 (Oil Completion Reports): Oil well completion documentation
  • Form G-1 (Gas Completion Reports): Gas well completion documentation
  • Plug Backs, Re-entries & Deepening: Complete filing for well modifications

Injection and Disposal Well Applications

Valor can prepare filings for injection and disposal well applications, including:

  • Form H-1 (Injection Wells): Underground injection control permits
  • Form W-14 (Disposal Wells): Saltwater disposal well permits
  • 1/4 Mile Radius Well Status Maps: Area well mapping
  • 1/2 Mile Offset Operator Maps: Operator notification mapping
  • Supporting Documentation: Attachments supporting the permit application

New Field Discovery and Field Transfer Applications

Filing research and applications for new field designations:

  • Form P-7 Applications: New field designation filings
  • 2.5 Mile Research: Comprehensive well research within 2.5 miles
  • Supporting Area Maps: Detailed geological mapping
  • Cross-Sections: Geological cross-section preparation
  • Pressure Data Maps: Bottom-hole pressure reports and analysis
  • Log Filings: Well log submissions for new reservoirs

Railroad Commission Research and Reproduction Services

Valor’s research department reproduces well data filed with the Railroad Commission back to 1919, with same-day research and expedited service typically available:

  • Well Data Reproduction: Applications to drill (Form W-1), completion reports (Forms W-2, G-1)
  • Inclination Reports: Form W-12 directional surveys
  • Cementing Reports: Form W-15 documentation
  • Plugging Reports: Form W-3 plugging documentation
  • Production History: Complete production data from initial completion
  • Test Data: Semi-annual and annual test data (Forms G-10, W-10)

NGPA Applications and Tight Gas Designation

Valor can prepare filings for Tight Gas Designation applications that provide reduced severance tax rates from the Texas Comptroller for qualifying gas well production.

Oil and Gas Proration Services

Valor can monitor oil and gas fields throughout Texas, including:

  • Maximum Allowable Assignments: Seeking the maximum allocation available under existing field formulas
  • Violation Management: Handling severances, shut-in orders, and overproduction notices
  • Relief Applications: Filing for cancellation of violation overage when possible
  • Market Demand Forecasts: Monthly operator forecasts for gas well gas in prorated fields
  • Balancing Applications: Production balancing and reduced rate authority requests

Production Reporting and Severance Tax Services

Monthly filings for Railroad Commission production reporting forms:

  • Producer's Monthly Report (Form PR): Both oil and gas wells
  • Frac Oil Movement (Form P-3): Oil movement requests
  • Initial Production Clearance (Form P-8): Oil/condensate production clearance
  • Monthly Skim Oil (Form P-18): Skim oil reporting
  • Severance Tax Incentives: SWR 50 (Enhanced Oil Recovery), SWR 101 (High Cost Gas), SWR 102 (Incremental Production)

Additional Specialized Services

Other filings Valor can handle include:

  • HB 2259 Compliance: Form W-3C and W-3X filings for inactive well requirements
  • Surface Commingling: Forms P-17/P-17A for multi-lease production
  • Flaring and Venting: Rule 32 exceptions and tank clearance (Form P-4)
  • Test on Inactive Wells: Form H-15 for wells over 25 years old
  • Annual Organization Reports: Form P-5 with required bonding documentation
  • Salt Water Hauler Permits: Forms WH-1, WH-2, WH-4, WH-5
  • Pipeline Permits: Forms T-4 and T-4B applications
  • Pit Permits: Form H-11 for pit maintenance and use
  • Lease Consolidation: Form P-6 and plats for lease consolidation/subdivision

Expert Hearing Exhibits and Data Reproduction

Reproduction of data submitted at Railroad Commission hearings, including field maps, isopach maps, structure maps, cross-sections, logs, reservoir MER data sheets, engineering data, drill-stem tests, disposal-injection well data, and hearing transcripts.

Why Operators Choose Valor for Regulatory Compliance

Valor’s regulatory specialists typically prepare filings across the Commission’s forms and hearing types, can give expert testimony at Rule 37 and Rule 38 hearings, and are typically available full time Monday through Friday. Regulatory work sits alongside the rest of Valor’s back office — accounting, JIB and revenue, land administration, and owner relations — and you typically approve disbursements and keep every operational and capital decision.

Getting Started

Engagements typically start with a scoping call about your wells, states, P-5 status, and upcoming filings and hearings. Valor then typically sends a proposal for how the work would run once you are a client.

Running a formal selection? Valor can answer your RFP.

Regulatory Compliance FAQ

Valor can file with the Texas Railroad Commission (TRRC, often RRC) for oil and gas operators. The TRRC is the state agency that regulates oil and gas in Texas, covering drilling permits, well completions, production reports, P-5 operator registration, pipeline safety, and well plugging; despite its name, it no longer regulates railroads.

Valor can prepare Form W-1 filings, including uncertified plats where the permit doesn't require a certified one. Form W-1 is the Application to Drill that the Texas Railroad Commission requires before an oil or gas well is drilled, deepened, plugged back, or re-entered.

Valor can file and renew P-5 organization reports for operators. The P-5 is the Texas Railroad Commission's operator registration, which an operator typically must keep current, with the required financial assurance, to operate wells in Texas.

Valor can prepare applications and exhibits and can give expert testimony for Rule 37 and Rule 38 matters. Rule 37 covers spacing exceptions to drill closer to lease lines or other wells than the field rules allow; Rule 38 covers density exceptions to drill on less acreage per well than normally allowed.

Valor can file both, typically with the required area and offset-operator maps. Form H-1 is the application to inject fluids into a productive reservoir, typically for enhanced recovery; Form W-14 is the application to dispose of saltwater and other oilfield fluids into a non-productive formation.

Valor can prepare P-7 filings with the supporting research, maps, cross-sections, pressure data, and logs. Form P-7 is filed to establish a new oil or gas field with the Railroad Commission and typically requires well research within 2.5 miles.

Processing times are set by the Railroad Commission and vary. As a typical range, simple completion reports (W-2, G-1) process in 1–2 weeks, while contested Rule 37 and 38 hearings can take 3–6 months. Expedited services are available for urgent applications.

Valor can file with the Oklahoma Corporation Commission, New Mexico's Oil Conservation Division, North Dakota's Department of Mineral Resources, Louisiana's Office of Conservation, Colorado's Energy & Carbon Management Commission, and the BLM on federal lands, and typically tracks those filings on the same compliance calendar.

Valor can coordinate with each operator's regulatory counsel on pooling, increased-density, and spacing matters, including OCC pooling notices, and typically prepares the supporting filings and exhibits.

Valor typically prices operator services from a standard price sheet: a baseline tiered by number of wells, plus variable charges for other types of work. For most small and mid-size operators, Valor's operator services can typically run 30–50% less than equivalent in-house staff.

Valor can answer an RFP for outsourced regulatory compliance, so you can compare providers against the same scope and questions before you commit.

Talk to Valor About Regulatory Filings

Tell us your states, well count, and what is coming due. A member of Valor's operator services team typically follows up to discuss your needs.

Key Takeaways

Page last reviewed: September 2026. Content is reviewed periodically and updated for accuracy.