Public Comment Period Open for Forms P-17 and P-17 A
October 15, 2025The Railroad Commission of Texas is accepting public comments on proposed changes to the following two forms:
- Form P-17, Application for Permit Exception to Statewide Rules 26 and/or 27
- Form P-17 A, Application for Commingle Permit Pursuant to Statewide Rules 26 and/or 27
These changes are being made to implement the Final Order in Oil and Gas Docket No. OG-25-00027634, the Application of BPX Operating Company (Operator No. 085408) to Consider Amending the Field Rules for the Phantom (Wolfcamp) Field, Culberson, Loving, Pecos, Reeves, Ward, and Winkler Counties, Texas, in which the Commission authorized an option for an exception to 16 Texas Administrative Code §3.32 if an operator meets certain criteria involving central production facilities, as defined in the field rules. The requirement to use Forms P-17 or P-17A is specified in Field Rule No. 9 of that Final Order.
Section 5 of each form adds a selection box in which an operator may select to affirm that “Proposed commingling will occur at a Central Production Facility for which Operator is making a Flaring Intensity Election. (Additional enforcement requirements are specified; see instructions).”
The proposed revisions to Forms P-17 and P-17A also include concurring changes to the instructions for both forms.
Proposed revisions also include several additional changes to the form instructions that would improve the clarity and usability of the forms.
The proposed revised forms will be available for public comment until 5 p.m. on November 14, 2025.
The forms and comment submission options can be found on the RRC website at https://www.rrc.texas.gov/forms/proposed-form-amendments/ under Oil & Gas Forms.
Oil & Gas Division staff will review the comments and make any necessary changes if needed. Staff will then present the forms to the RRC Commissioners at an open meeting and request adoption.
