Relating to the affirmation required to be made by an operator as part of an application to the Railroad Commission of Texas for an extension of the deadline for plugging an inactive well; providing an administrative penalty.

Contracts

• Master Service Agreements (MSAs): Review MSAs with electrical contractors and remediation vendors. You must ensure they have the capacity for rapid deployment to clear sites prior to your regulatory filing deadlines.
• Utility Agreements: Review terms with electric cooperatives. You may need to amend agreements to allow for expedited disconnects without triggering punitive reconnection fees if the well is reactivated later.

Hiring/Training

• Regulatory Staff: Train regulatory managers to halt automatic W-3X renewals. They must not sign the affirmation without documented proof of field status.
• Field Operations: Field pumpers and superintendents must be trained on the specific removal requirements for wells inactive for 10+ years (removal of trash, surface equipment, and operator-owned electric infrastructure).

Reporting & Record-Keeping

• Form W-3X: This form now carries heightened liability.
• Evidence Packages: Implement a mandatory "Proof of Termination" protocol. Require a timestamped photo of the disconnected meter loop or a confirmation letter from the utility provider to be attached to the internal file before the W-3X is submitted.

Fees & Costs

• Administrative Penalties: The law establishes a penalty of up to $25,000 per violation for providing the affirmation without performing the required work.
• Operational Costs: Budget for immediate electrical contractor call-outs and surface remediation crews for all wells approaching the 10-year inactivity mark.