September 4, 2020 

The Railroad Commission of Texas Attention: Rules Coordinator PO BOX 12967 Austin, Texas 78711-2967 

Filed Via Email to rulescoordinator@rrc.texas.gov  

Re: bp and Shell comments for proposed amendment to the Statewide Rule 32 Exception Data Sheet to improve the effectiveness of the RRC’s Rule 32 exception program 

BPX Operating Company (“bp”) and SWEPI LP dba Shell Western E&P (“Shell”) appreciate the opportunity to submit the following joint comments to the Railroad Commission of Texas on the proposed amendment to the Statewide Rule 32 Exception Data Sheet. Both bp and Shell appreciate the willingness of the Commission to work with operators and industry trade associations, including the collaborative work of the Texas Methane and Flaring Coalition (TMFC), to identify, assess, and recommend opportunities and best practices to improve data quality and reduce flaring in Texas.  We support the initial findings and recommendations of the TMFC and applaud the Commission’s effort to revise and update Statewide Rule 32 specific to the exception data sheet.  Our companies believe reducing flaring in Texas is an operational and environmental imperative and we look forward to working with all stakeholders to deliver material and measurable results. 

As supporters of the World Bank’s Zero Routine Flaring initiative, we seek the elimination of routine flaring of natural gas globally. And in Texas, where there is a history of industry innovation and leadership, we believe there is a real opportunity for the state to set the bar for others to follow. We encourage the Railroad Commission of Texas to support an ambition of zero routine flaring in Texas.  

We offer four guiding principles, attached to this letter, that the Railroad Commission could consider as a policy framework to support the achievement of this ambition. These principles include: 

(1) Incentivizing continuous improvement efforts that link ambitions to real outcomes by measuring interim and long-term progress.

(2) Improving flaring data per the recommendations of the TMFC to enhance transparency and inform progress. 

(3) Enhancing regulatory oversight through standards and regulatory mechanisms that incorporate assurances to reduce flaring.

(4) Facilitating collaboration with midstream entities that fosters collaborative action, which is essential to ensure sufficient midstream infrastructure is in place and available. 

We look forward to working with the Commission and all stakeholders to address routine flaring in Texas and welcome the opportunity to build upon the work that is already underway. 

Respectfully, 

David Lawler Chairman and CEO, BP America Inc. 

Gretchen Watkins President, Shell Oil Company 

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