TXOGA Statement on Railroad Commission Weatherization Rules

August 30, 2022

The following can be attributed to Todd Staples, president of the Texas Oil and Gas Association:

“Senate Bill 3, passed by the 87th Legislature, strengthened the electricity grid and the natural gas supply chain. The Texas Railroad Commission (RRC) has finalized rules regarding weather emergency preparedness standards for natural gas facilities, and we appreciate the RRC’s effort to carry out its legislative mandate.

“Many operators already have measures in place to operate in severe weather, and weatherization is just one element in this discussion. Critical load designations, increased communication among all parties in the natural gas and electricity supply chains, weatherization of generators, and firm contracting for natural gas supply, transportation, and storage are far more impactful in securing the electricity grid.

“Reports from ERCOT, the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) concluded that fuel limitations were 12% to 15% of the reason for outages and derates of power generators during Winter Storm Uri. Natural gas was not the primary cause of problems. Any over-emphasis on weatherization of natural gas facilities is concerning because, regardless of the level of weatherization, during extreme weather we can expect these largely unmanned upstream production sites to lose 10% to 30% of daily production. These are field operations and not factory settings. Stopping production is a necessary option for environmental and safety reasons, and flexibility must be allowed in rulemaking for operators to maintain safety. ”


Founded in 1919, TXOGA is the oldest and largest oil and gas trade association in Texas representing every facet of the industry.

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