Flaring Reporting Requirements: RRC Statewide Rule 32 Explained
Updated March 2026 · 9 min read
Flaring and venting of natural gas has become one of the most scrutinized issues in Texas oil and gas regulation. The Railroad Commission of Texas (RRC) regulates flaring primarily through Statewide Rule 32, which prohibits the wasteful flaring of gas and requires operators to obtain authorization before flaring beyond certain thresholds.
With increasing public attention on flaring and the RRC tightening enforcement, understanding these requirements is essential for every Texas operator.
What Is Statewide Rule 32?
Statewide Rule 32 (16 TAC Section 3.32) addresses the flaring, venting, and waste of gas in Texas. The rule's fundamental principle is that gas waste is prohibited — operators must make reasonable efforts to capture and market produced gas rather than flare or vent it.
Under Rule 32, operators can flare gas without specific authorization only during initial completion and testing for a limited period (typically 10 days). Beyond that, operators must either connect to a gas gathering system, use gas for on-lease operations, or obtain a flaring exception from the RRC.
Flaring Exception Process
When You Need an Exception
You must apply for a flaring exception if you need to flare gas beyond the initial completion period, your gas gathering connection is delayed, pipeline capacity is insufficient to handle your production, or equipment failure requires temporary flaring. Exceptions are granted for specific time periods and are not permanent authorizations.
How to Apply
Flaring exception requests are filed electronically through the RRC's online system. The application must include the specific reason for flaring, the estimated volume of gas to be flared (in MCF per day), the duration of the requested exception, documentation of efforts to connect to a pipeline or find alternative gas use, and a plan for ending flaring.
The RRC reviews each application and may approve, deny, or modify the request. Approval is not guaranteed, and the RRC has become increasingly stringent about granting exceptions, particularly for operators who have not demonstrated genuine efforts to reduce flaring.
Volume Reporting Requirements
Operators must report flared gas volumes to the RRC through several mechanisms:
Monthly Production Reports
Flared gas volumes must be reported on Form P-2 (gas) or the gas disposition section of Form P-1 (oil). Volumes must be reported accurately in MCF and classified as either flared or vented. Underreporting flared volumes is a separate violation from unauthorized flaring.
Flaring Reports
Operators with active flaring exceptions must submit periodic flaring reports as required by their exception conditions. These reports typically include daily flaring volumes, the reason flaring continued, progress toward connecting to a pipeline, and an updated timeline for ending flaring.
TCEQ Emissions Reporting
Flaring also has TCEQ implications. Flared gas produces emissions including NOx, CO, VOCs, and SO2, which must be included in your TCEQ emissions inventory. Operators with air permits must ensure their flaring volumes are consistent between RRC reports and TCEQ emissions calculations.
Measurement Requirements
The RRC expects operators to measure or reasonably estimate flared gas volumes. Acceptable methods include orifice meters or ultrasonic meters on the flare line, estimation based on well test data and production rates, and calculation using gas-oil ratio (GOR) and oil production data. The RRC has signaled that it expects more precise measurement over time, and operators who rely solely on rough estimates may face scrutiny.
Penalties for Noncompliance
The consequences of flaring violations have increased significantly:
- Unauthorized flaring: Penalties can range from $1,000 to $10,000 per day, depending on volume and duration
- Failure to report: Inaccurate or missing flaring reports carry separate penalties
- Waste of gas: Willful waste of gas can result in well shutdowns and production curtailment orders
- Permit complications: Unresolved flaring violations can block new drilling permits and transfers
The RRC has also increased its use of aerial monitoring and satellite data to identify unreported flaring, making it harder for operators to underreport or avoid reporting altogether.
Best Practices for Flaring Compliance
- Begin gas marketing negotiations before completing a well — do not assume pipeline access will be available
- Install metering on flare lines to get accurate volume data
- File flaring exception requests well in advance of when authorization is needed
- Ensure RRC and TCEQ flaring/emissions data are consistent
- Track exception expiration dates and renew before they lapse
CompliantIntel tracks your flaring exception dates, reporting deadlines, and cross-references your RRC and TCEQ filings to ensure consistency.