How to File for an RRC Flaring Authorization
When flaring beyond the narrow allowances is unavoidable, a Texas operator has to seek authorization from the Railroad Commission rather than simply keep flaring. This guide walks through what that process involves in practice - understanding the basis you are claiming, justifying why flaring is necessary, and backing the request with data - so the filing stands on evidence. It defers to qualified regulatory personnel and the Commission's current procedures on the exact forms and requirements, which change and are outside this guide's scope.
RRC Flaring Exception Filing in one line: To seek Railroad Commission flaring authorization under Rule 32, first confirm the flaring does not already fit an allowance, then prepare a request that identifies the well, explains why flaring or venting is necessary rather than avoidable, states the volume and duration involved, and supports it with metering data. The stronger the justification and the more solid the volume evidence, the more defensible the authorization request.
Confirm You Actually Need an Authorization
Before preparing anything, determine whether the flaring genuinely requires authorization or whether it already fits within an allowance the rule provides. Some short-duration, operationally driven flaring is contemplated without special authorization, and there is no point building a request for flaring that is already covered. Making this determination with qualified personnel against the current rule is the necessary first step, and it flows from understanding what Rule 32 governs, covered in the explainer on Statewide Rule 32.
If the flaring does exceed the allowances, identify the situation driving it: gas that cannot yet be connected to a sales line, a temporary constraint downstream, well testing, or another operational reality. The nature of the need shapes the request, because the Commission is being asked to authorize a departure from the default of conserving the gas, and the justification has to explain why conservation is not presently feasible.
This is also the point to be honest about duration and volume, because an authorization is bounded. A request for a defined, limited period with a clear plan to end the flaring - by connecting the gas, installing recovery, or ceasing production - is more defensible than an open-ended one. The recovery option that can end the need is covered in the explainer on flare gas recovery.
Build the Justification and the Volume Basis
The core of the request is a justification: why must this gas be flared rather than conserved, and for how long? A strong justification is specific and factual - the pipeline is not yet built, the processing capacity is constrained, the well is being tested - rather than a general assertion that flaring is convenient. It should also address what the operator is doing or plans to do to reduce or end the flaring, because the rule's orientation is toward limiting the release.
Alongside the justification comes the volume basis: how much gas is being or will be flared. This is where metering data does the heavy lifting, because a request grounded in measured flare volumes is far more credible than one based on estimates. Knowing the actual flared volume over time, from the flare gas flow measurement covered in the explainer on the flare gas flow meter, lets the operator state the volume accurately and demonstrate it against any limit the authorization carries.
A cloud SCADA platform such as Merobix supports this by having already trended and retained the flare gas flow and flame status, so the volume basis for the request is drawn from stored data rather than assembled from scratch. That same retained record then supports the ongoing reporting once an authorization is in place, described in the explainer on the flaring and venting report, so the data that justified the request also demonstrates compliance with it.
Submit, Track, and Keep the Record
With the justification and volume basis prepared, the request goes to the Commission through its current process, and the operator should follow the Commission's procedures and any forms it requires, which are outside this guide and best confirmed with qualified regulatory personnel. The important discipline on the operator's side is treating the authorization as a tracked obligation with a defined scope and end, not a permanent license.
Once an authorization is granted, it typically carries conditions - a volume limit, a time limit, or reporting expectations - and the operator has to operate within them and be able to show it. This is where the same metering that justified the request proves ongoing compliance: continued measurement of flare volume against the authorized limit demonstrates the operator stayed within scope, and the retained history is the evidence.
Keep the whole package together: the basis for needing authorization, the justification, the volume data, the authorization and its conditions, and the ongoing measurement showing compliance. Because a well's flaring is scrutinized against its disposition records, having that complete, data-backed trail is what turns an authorized flare from a compliance risk into a documented, defensible situation. Managing the flaring down over time also connects to the accounting in the explainer on lease fuel and flare accounting.
Frequently Asked Questions
When do I need to seek RRC authorization to flare?
When the flaring exceeds the narrow allowances the rule provides for short-duration, operationally driven situations. If the flaring already fits within an allowance, no special authorization is needed; if it does not - for example ongoing flaring because gas cannot yet be connected to a sales line - the operator has to seek the Railroad Commission's authorization to continue. Determining which case applies should be done with qualified regulatory personnel against the current rule, since building a request for flaring that is already covered wastes effort and flaring without a valid basis risks non-compliance.
What makes a flaring authorization request defensible?
A specific, factual justification for why the gas must be flared rather than conserved - the pipeline is not yet built, processing is constrained, the well is being tested - paired with an accurate, measured volume basis and a defined, limited duration with a plan to end the flaring. Requests grounded in metered flare volumes rather than estimates are far more credible, and one that shows what the operator is doing to reduce or end the flaring aligns with the rule's orientation toward limiting the release. Open-ended requests with vague justifications are weaker.
How does metering data help after an authorization is granted?
An authorization typically carries conditions such as a volume limit, a time limit, or reporting expectations, and the operator has to operate within them and demonstrate it. The same flare gas metering that justified the request then proves ongoing compliance: continued measurement of flared volume against the authorized limit shows the operator stayed within scope, and the retained history is the evidence. Because a well's flaring is scrutinized against its disposition records, having a continuous, data-backed measurement trail turns an authorized flare into a documented, defensible situation rather than a risk.
Automation services
Need help turning this into a working system?
Merobix integrates SCADA, programs Allen-Bradley and Siemens PLCs, and designs and fabricates industrial control panels.
Meeting requests are reviewed before confirmation.