Feature
March 2015, Vol. 242, No. 3
Texas Permiting Rules Post-Denbury Green
The Texas Railroad Commission adopted new rules in December concerning pipeline permit applications involving 16 Texas Administrative Code §3.70. It has been three years since the state Supreme Court’s opinion in Denbury Green, which took a dim view of the commission’s “check the box” rules regarding Form T-4 pipeline permit application which automatically created common carrier status to the pipeline operator.