Speaking Engagements November 7, 2025

New Upstream Pit Permitting Rules

Speakers

Gerald D. Higdon Case Towslee

Join Troutman Pepper Locke attorneys Jerry Higdon and Case Towslee as they detail the latest waste permitting rules from the Railroad Commission, effective July 1st. This insightful discussion explores the new registration and permitting requirements for Schedule A and Schedule B pits, the implications for construction and groundwater monitoring, and how these new rules affect due diligence, compliance, and transaction timelines in the upstream oil and gas sector. Learn what operators, buyers, and sellers need to know to navigate this changing landscape.

  • 0:30 – What are the July 1st rules, for Schedule A (well-associated) and Schedule B (produced water recycling) pits?
  • 2:00 – What are the new registration obligations?
  • 2:30 – What are the construction requirements for groundwater proximity and how groundwater data is obtained?
  • 3:30 – What are the new rules for the timing of pit closures and long-term monitoring requirements?
  • 4:00 – How do the new rules affect due diligence in connection with transactions 
  • 5:00 – Will sellers and buyers be more open to subsurface investigations and sampling due to new closure requirements 
  • 6:10 –What are the timing and compliance challenges involved with permit transfers, and how might they affect deal structuring?
  • 7:13 – How do the new requirements affect site and records inspections?
  • 8:17 – What are the potential solutions for transaction timing and environmental compliance?

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