NTO - Updates to T-4 Requirements

January 02, 2025

There are several important updates for T-4 requirements. They are as follows:

Form C-LTR POPS Cover Letter: The December 2024 version is the most recent and is required.
T-4B Pipeline Transfer Certification: The August 2024 version is the most recent and is required.
A Guide to Shapefile Submissions: Version 2024.12.12 is the most recent.
Amendments to 16 TAC 3.70 have been adopted as of December 9, 2024. The adoption notes can be found here:
https://texas-sos.appianportalsgov.com/rules-and-meetings?$locale=en_US&interface=VIEW_TAC_SUMMARY&queryAsDate=01%2F14%2F2025&recordId=222535.
Per 16 TAC 3.70(r)(1), operators with active intrastate natural gas gathering pipelines must amend their T-4 permits by March 31, 2025, to include the required attributes and indicate the appropriate Type of A, B, C, or R. Failure to do so could result in a $5,000 penalty per permit in accordance with 16 TAC 3.70(p).
Per 16 TAC 3.70(r)(2), 2025 renewal applications submitted for all intrastate gas permits must include an attestation statement regarding the natural gas gathering requirements.
- To assist operators with the attestation statement requirement, a sample Form C-LTR POPS Cover Letter has been pre-filled with statements in the Additional Information section on page 3 of the form. Operators should delete the statements that do not apply. The sample 2025 Renewal C-LTR is available for download in the Other Samples section on this page: https://www.rrc.texas.gov/pipeline-safety/pipeline-safety-forms/#PipelinePermitting.

Updated resources can be found on our Permitting & Mapping web page here: https://www.rrc.texas.gov/pipeline-safety/permitting-and-mapping/.

If there are any questions, please contact us at POPS@rrc.texas.gov or (512) 463-6802.