Frequently Asked Questions Regarding Forms CI-D and CI-X

Only list the oil lease number.

The lease location can be denoted by the latitude and longitude of the gate entrance to the lease.

The forms do not currently require designating the location of a pipeline itself. You only need to identify the location of the associated compressors, control centers, regulator stations, and/or meter stations then identify the T-4 permit number of the pipeline served by that compressor, regulator station, or meter station, as applicable.

Yes. You may have multiple facilities along the same pipeline segment T-4. It is acceptable for the T-4 permit number to be entered in multiple rows.

No. If you intend to apply for an exception, only file Form CI-X. If you are seeking an exception for more than one facility, list all of the facilities on a single Form CI-X attachment. Be sure to include a written justification for the exception for each facility listed and to submit the $150.00 filing fee. The filing fee is applicable for each Form CI-X–there is not a separate fee for the attachment. Make sure the Form CI-X is filed by the same deadline as the deadline for the CI-D. The upcoming deadline is September 1, 2022. Filing deadlines are March 1 and September 1 of each year.

Yes. You are required to continue to apply for the exception for a facility that was previously granted an exception. Please include with your materials an explanation that the facility was previously granted an exception and whether the circumstances of the facility have changed. You must still include a justification and evidence with your Form CI-X. You are not required to pay the fee again.

Please see Sec. 25.52(h)(1).

A searchable and downloadable list is available at this link (under Critical Natural Gas):
https://www.puc.texas.gov/industry/electric/directories/Default.aspx

Utility dual feed capability refers to the ability of a customer to receive electric service from two or more independent sources.

Do not change the CI-D or CI-D Attachment prior to sending it to your electric utility. Send the same Form CI-D and CI-D Attachment that you filed with the Railroad Commission.

If your CI-D Attachment contains some facilities that are only critical gas suppliers, then leave the cells that request electric provider information for that facility blank. Those cells do not apply to that facility because a facility that is only a critical gas supplier does not require power to operate. However, those same cells must be completed for a critical customer (a facility that does require power to operate). When the electric utility receives the Form CI-D and CI-D Attachment, the utility will see that cells showing electric provider information are blank for certain facilities but completed for others, and will know that the facilities that have blank cells do not need power to operate.

If a Lease ID has not yet been issued, leave the field blank and update it on the next Form CI-D filing after the number has been issued.

Attach a written justification in accordance with §3.65(f) to Form CI-X in support of the Form CI-X exception application. For example, you can create one PDF document that includes the Form CI-X, followed by pages that contain your written justification and evidence. The Form CI-X, written justification attachment and CI-X attachment can be filed through the RRC Online System. The written justification must include objective evidence to support it. Ensure your justification includes objective evidence to enable staff to verify your justification or your exception request will likely be denied.

For Column E: If a gas well subject to §3.65(b), provide the RRC gas ID number (6-digit) and the average daily gas production for the well from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

For Column G: If an oil lease subject to §3.65(b), provide the RRC oil lease number (7-digit) and the average daily gas production for the lease from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

Yes. Rule 3.65(b)(1) sets forth the criteria for determining whether a facility is critical. If a party operates any facilities of the type listed in §3.65(b)(1)(A) – (H), then those facilities are designated as critical during an energy emergency. For gas wells (§3.65(b)(1)(A)), those wells that produce in excess of 15 Mcf/day are considered critical. Please see §3.65(a)(3) for the six-month method to calculate a well or lease’s production amounts for purposes of the rule.

If a well does not have six months of production, then per the instructions for Form CI-D, the operator shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test of the well has not yet filed a production report.

Tier 1 facilities are certain natural gas facilities that are included in the Public Utility Commission of Texas’ guidance document on load shed tiers. This guidance document only applies to electric utilities for use in prioritizing load shed to natural gas facilities.

If a Saltwater Disposal Well services one or more of the natural gas facilities listed in Tier 1, answer “Yes” in Column R. Tier 1 facilities are:

A.

• Pipelines that directly provide natural gas to ERCOT identified Black Start Service facilities and other natural gas fired electric generation;
• Natural gas local distribution company critical pipelines or pipeline facilities,
• Underground natural gas transportation and storage facilities;
• Natural gas liquids transportation and storage facilities; and
• Associated pipelines, compressor stations, and control centers for facilities in Tier One A.

B.

• Natural gas wells and oil leases producing natural gas in the amount of 5000 Mcf/day or greater;
• Gas processing plants with a capacity of 200 MMcf/day and greater;
• Associated pipelines, compressor stations, and control centers for facilities in Tier One B; and
• Associated saltwater disposal wells supporting the wells and leases for facilities in Tier One B.

You may view the entire Guidance Document on the PUCT website here: https://www.puc.texas.gov/industry/electric/cng/documents/Critical%20Natural%20Gas%20Guidance.pdf.

Yes. It does not matter whether a facility requires electricity to operate or not—they are subject to the requirements of §3.65 if they operate a facility of any of the types listed in §3.65(b)(1)(A)-(H), which are defined as Critical Gas Suppliers. Critical Gas Suppliers file Form CI-D and CI-D Attachment with the RRC.

A Critical Gas Supplier that requires electricity to operate is defined as a Critical Customer in §3.65. Critical Customers fill out the Electric Utility Information, in addition to the other sections, in the CI-D attachment. Critical Customers are required to provide Form CI-D and CI-D Attachment to their electric utility, in addition to filing with the RRC.

If you have a facility such as a gas well or an oil lease that is currently not on production, you do not need to include that facility on your CI-D filing. In the event that you return the facility to production, it may be necessary for you to add it to the next filing following its return to production, to the extent its production exceeds the volumetric thresholds set forth in §3.65(b)(1).

Yes.

The Commission will track the facilities that do not comply with §3.65. Facilities that do not comply will go through the Commission’s enforcement process. Note that Commission Rule §3.107 sets out the minimum penalties associated with a failure to file. The minimum penalty associated with a failure to file a CI-D or CI-X with the Commission is $1,000 and the minimum penalty associated with a failure to submit the critical customer information to your utility is $2,500.

The RRC online filing system will catch some clerical errors and notify you during the online filing process. RRC staff will also review for clerical errors and help you resolve them.

Yes, if you exceed the volumetric thresholds provided for in Rule 3.65(b)(1)(A) or (B).

Rule 3.65 contains requirements for facilities to be designated critical mainly for load shed planning and power restoration purposes. Critical designation forms Form CI-D and/or CI-X are required to be submitted to the RRC, and Critical Customers must also submit their CI-D form and attachment to the facility’s electric provider.

Rule 3.66 contains the RRC’s proposed weatherization requirements. Rule 3.66 has not been adopted yet but will likely go into effect in September 2022.

Pursuant to Senate Bill 3, for non-pipeline facilities, only those facilities designated critical in accordance with Rule 3.65 AND are also on the Electricity Supply Chain Map are subject to Rule 66 requirements.

For gas pipeline facilities, those on the Electricity Supply Chain Map AND directly serve natural gas electric generation facilities operating solely to provide to the electric grid for the ERCOT power region, or for the ERCOT power region and an adjacent power region, are subject to Rule 3.66 requirements.