DNA OF A TEXAS PERMIT

We said we’d be transparent on our permit path, so here’s the latest.This week we had a nice call with the nice folks at RRC. The number one question that has become the elephant in the room — or in oilfield if you like — is this question:

Who owns that water once it’s treated/cleaned and is put to beneficial use? The RRC checked with their internal lawyers for the answer.

Quick, let’s see if you can guess the answer for the Texas Permit Trivial Pursuit: Who owns produced water that has had its constituents and purpose changed?

Well….if your answer was “Nobody knows” then you’re the winner!

Here’s what the RRC, who has jurisdiction over the water says, “After discussions with the RRC attorney, the RRC does not make determinations on water ownership. You will need to discuss this with a water rights attorney in the State of Texas.”

Seem like the State of Texas itself should know the answer to this question.

Meanwhile, in West Texas, it’s not raining and the cotton is burning.

IT’S A “TOTAL” ECOLOGICAL SOLUTION - EVEN IF YOU ONLY CARE ABOUT ONE PART

We talk about the total solution, but you (rightly so) only care about your interest. So, if you have water you’re trying to dispose of, you’re a part of the Total.

If you have land with wells and you could use some water, you’re part of the Total. You’re a tech firm, a regulator, a government official, or a data center, you can connect in and be a part of something bigger.

When we all work together, the end result is greater than the sum of its parts. 

THE TOTAL ECOLOGICAL SOLUTION IS JUST ONE BIG CAKE

The way you bake a great cake is with a great recipe.

You have to add a cup of Permitting, Data, Landowners Relations, Efficient Water Treatment, AgWaterSoilSolutions, Safety, and a Patented Method to land apply water. You mix it all up and put it in the oven. That’s what we do.

We are working on gathering all these ingredients.

In Wyoming, the cake is in the oven, baking. In Texas and New Mexico, we got a lot of the ingredients in the panty. But working on a few more.

Come on, folks, let’s bake us up some Total Ecological Solution.

IT’S THE DATA, STUPID

Once upon a time, most people farmed. Then, most people worked at a factory.

These days, we’re in the age of information and you’d be surprised at how much of your day is based on data you receive or data you gather. The amount of information you consume in one day is more than your great-grandfather consumed in his lifetime - especially if he was a steward of the soil. Those guys mostly had meetings with cows and not co-workers.

That’s why the key to Total Ecological Solution is the collection and distribution of data. What’s the soil like? What’s the amount of moisture in the soil? What water treatment is happening, when, how much, and to what levels? All that’s necessary and all that’s data.

These days I farm data a heck of lot more often than I farm anything else.

YOUR KIDS AND GRANDKIDS WILL THANK YOU

….If you join the progress of Total Ecological Solution. Angry Swedish teenagers aside, we do want the next generation to have land that is thriving. And that’s only going to happen with a Total Ecological Solution. 

We’ve been playing the Big Oil and Big Eco games too long. 

Let’s get to work to turn this brown, arid land green and clean up the sky!

DNA OF A TEXAS PERMIT – THE EYES OF TEXAS ARE UPON YOU

We thank the RRC for their response to our narrative they had requested. And with it, we identify the real issue, because this is not our first rodeo on the bucking bulls of government agencies. In addition to the standard info that is easy to answer, they add, “There is the questions of liability and delineations of responsibilities that must be addressed.”

We couldn’t agree more – that’s why we went to the RRC in the first place to officially find out this very question. Because the EPA and TCEQ didn’t know and told us to talk to the RRC. 

So, since no one seems to know, we say that our partner Wilson Farms owns the water and takes all liability.

Anyone have any different insight on this? 

You see, all the facts about the source of produced water, volumes, and water cleaning parameters don’t matter until who owns the water and holds liability for it is figured out.  

Meanwhile, the cotton on Wilson Farms in Midkiff are burning from the lack of water. 

CAN AND SES ARE OUT OF THIS WORLD

We’re privatizing environmental stewardship. Kind of how Elon Musk privatized space travel. And, like Elon, we’re going to be doing it with NASA because their satellites can tell us how much carbon is in your backyard - or ranch. 

Privatizing is better than a government led program because, well, we’ve met government agencies. The Carbon Asset Network (CAN) and Synergy for Ecological Solutions (SES) working with YOU is the way forward. 

Come join the free enterprise system to clean our air— it’s not rocket science. 

HELPING THE ENVIRONMENT SHOULD NOT BE A TAX SCHEME

But come on, folks, that’s what Cap and Trade is.

Here’s the better way -- a free enterprise method for those who want to join in to help the environment. Carbon Asset Network (CAN) working with Synergy for Ecological Solutions (SES) is building just such a method along with Wyoming Stock Growers Association, landowner partners, and YOU to help regenerative ag and our air quality.

Because together we CAN.

Thanks, IRS, but you can sit this one out. 

DNA OF A TEXAS PERMIT

Don’t you hate waiting? In our pursuit of a permit to land-apply cleaned produced water in Texas, we find ourselves waiting. Maybe that’s just how it is. Things take time. So, we wait.

Is the delay because the agency doesn't know what to do with something new? Is it because they're short-staffed and things just sit on desks? Is it a political agenda where the energy industry wants control of the water? Hard to say. 

Meanwhile, our cotton farmer partner is pulling in less cotton of less quality because there’s a drought in West Texas. 

The bureaucratic wheels which turn slowly haven’t thought about cotton or droughts today. A drought to them just means they don’t have to carry an umbrella. 

For ag, it’s a mater of making it or not, losing the farm or not. And if we could take the billions of gallons from produced water and clean it and land apply, our friend the cotton farmer could also only worry about carrying an umbrella or not.

But, instead, we wait.

THE DNA OF A TEXAS PERMIT

Here’s the status of our story to gain a Texas permit to land-apply cleaned by-product (our definition) produced water in arid West Texas for non-consumable ag, soil health, and conservation. 

REGULATORY/EPA: We spoke to EPA Region 6. Does EPA have primacy over Texas? Well, sorta.

He told us to talk to TCEQ (Texas Commission for Environmental Quality--we might have to create a glossary for the acronyms) Does TCEQ has primacy over Texas? Well, sorta.

REGULATORY/TCEQ: We spoke to the TCEQ and they told us to talk to the RRC (Railroad Commission). Does the RRC has primacy over Texas? Well, sorta.

REGULATORY/RRC: We spoke to the nice folks at RRC who asked for a narrative, which we sent. 

ENVIRONMENTALIST POINT OF VIEW: Our friends at Big Eco, we’re majoring on the facts and not our opinions.

ENERGY POINT OF VIEW: Our friends at Big Oil aren’t paying attention. Yet.

AG POINT OF VIEW: Meanwhile, Wilson Farms had to potentially abandon 2500 acres of cotton because there’s a drought and the alphabet soup of agencies so far hasn’t done enough to get this clean water to him.

But, the adventure isn't over yet. As they said in Tombstone, “We’re coming and hell’s coming with us.”

#esg #csuite #rrc #texas #midstream #sustainablity #regenerativefarming