Emergency Operations Plan FAQ

On November 30, 2021, RRC commissioners adopted rules for critical designation of natural gas infrastructure to help protect Texans in energy emergencies. The new rules implement provisions in Texas House Bill 3648 and Senate Bill 3 and define natural gas facilities that would be designated as critical gas suppliers and critical customers.

• Critical gas suppliers include, but are not limited to, gas wells, oil leases that produce gas, natural gas pipeline facilities, underground natural gas storage facilities and saltwater disposal facilities.
• Critical customers, which are a subset of critical gas suppliers, are facilities that require electricity to operate. These operators submit critical customer information to their electric utilities so that their electric utilities have the correct information for purposes of supplying power to the facilities.

Operators are required to submit an Emergency Operations Plan (EOP) because they operate at least one or more facilities that: (1) produce, treat, process, pressurize, store, or transport natural gas; and (2) are, or will, be included on the Texas Electricity Supply Chain Security and Mapping Committee map, which had its first iteration adopted on April 29, 2022.

This rule applies to you if you received the notification letter from the RRC dated May 15, 2024.

• The notification letter provides guidance on what should be included in an EOP.
• The RRC will not provide an EOP template; operators may structure their EOP to meet their particular needs.

If you believe you are subject to the rule and did not receive the notification letter, please contact RRC’s Critical Infrastructure Division unit at 512-463-6737 or by email at CID@rrc.texas.gov.

If you received the notification letter and believe you are not subject to the rule, please contact RRC’s Critical Infrastructure Division unit at 512-463-6737 or by email at CID@rrc.texas.gov.

You may contact the RRC’s Critical Infrastructure Division unit at 512463-6737 or by email at CID@rrc.texas.gov.

Applications for exception require objective evidence proving reasonable cause and justification, which will be reviewed, and RRC staff can deny an application for exception.  See Form CI-X, Critical Designation Exception Application, and related instructions available on the RRC website at https://www.rrc.texas.gov/critical-infrastructure/critical-infrastructure-forms/.

Details:

• Each EOP should provide at a minimum the information specified in the notification letter. For more details, reference the EOP Guideline available on the RRC website at https://www.rrc.texas.gov/media/o1ziuu4y/eop-guideline.pdf.
• If your company has more than one EOP, please combine them into one submission.
• The deadline for filing the EOP is August 1, 2024.
• If your EOP has confidential information, you may file a redacted copy, but you must file separately an unredacted filing for staff review. Please see the notification letter for guidance.

The electricity supply chain map is not available to the public. The map is confidential under state law due to the nature of the sensitive information it contains.

The presentation is available on the RRC website at https://www.rrc.state.tx.us/media/hgqo453t/eop-webinar-may-2024.pdf

EOPs will be reviewed under the notification letter criteria.  EOPs that meet all the criteria will be approved.  EOPs that do not satisfy all the criteria will be returned as incomplete.

Your EOP is considered public information by law except for portions that contain information that is considered confidential under Chapter 552, Government Code.  Pursuant to Texas Utilities Code § 186.008(g), if portions of an EOP are designated as confidential, the EOP shall be provided in a redacted form for public inspection with the confidential portions removed.  To the extent your EOP contains confidential information under Chapter 552, Government Code, you are required to submit two versions: (1) an unredacted EOP for the Commission’s review; and (2) a redacted version of the same EOP.

You may contact the RRC’s Critical Infrastructure Division unit at 512463-6737 or by email at CID@rrc.texas.gov.

We will mail out the EOP reviewal letters after the due date in August, electronic versions will be uploaded to the Operators Letters Dashboard on the RRC Online System.