ultimately preventing waste migration through the subsurface rock formations and trapping the water until it evaporates. See id . While effective, disposal via injection comes with both monetary expenses and environmental concerns. See Texas Produced Water Consortium, supra , at 7; Market Snapshot: Produced Water Management, Dawnbreaker (Dec. 21, 2022), estimating $0.60–$0.70 per barrel disposal vs. $2.55–$10 per barrel for treatment, with gap expected to narrow. The link between seismic activity and produced water disposal wells has caused the RRC to tighten restrictions on deep injection disposal. See id. In response, producers have shifted to injecting water into shallower rock. See Permian Basin Wastewater Risks Threaten Oil Output , GlobalData via Yahoo! Fin. (May 23, 2025). Water levels in this shallow rock have become so substantial, they risk breaching wells, swelling and rupturing the ground, and contaminating water sources. See id . The RRC has acknowledged this problem, and in May 2025 announced enhanced guidelines to go in effect June 1, 2025, for disposal wells in the Permian Basin. See RRC Issues Enhanced Guidelines for Permian Basin Disposal Wells , Tex. R.R. Comm’n (May 16, 2025). These guidelines place limits on the maximum water pressure, limits on the maximum daily water injection volume, and require operators to assess old or unplugged wells to ensure that produced water does not escape through wellbores. See id . With decreases in water availability and tightening of guidelines by the Railroad Commission on the disposal of produced water in both shallow and deep injection zones, something has to be done to address Texas’ water woes.
Corn Bd., https://nebraskacorn.gov/cornstalk/ sustainability/aquifer-101/ (last visited Aug. 14, 2025). In 2019, more than 4.4 million acre-feet were pumped from the Ogallala Aquifer, accounting for sixty-seven percent of water pumped from major aquifers. See Water Is Good for Texas, supra. Currently, we are drawing from this aquifer at 6.5 times its recharge rate. See Dylan Baddour, To Ease Looming West Texas Water Shortage, Oil Companies Have Begun Recycling Fracking Wastewater , Tex. Tribune (Dec. 19, 2022). However, the current approach to the Ogallala Aquifer is one of “managed depletion.” See id . Managed depletion is a strategy that involves deliberately using the aquifer until it is effectively exhausted. See id . While the Ogallala Aquifer is primarily used for irrigation, this intentional depletion is accelerating Texas’s path toward a serious water shortage. See Water Is Good for Texas, supra note 25. The Ogallala Aquifer isn’t the only major water source in the Panhandle and West Texas. See id. The Pecos Valley and the Edwards-Trinity Plateau Aquifers supply most of West Texas. While mainly supplying water for irrigation, both aquifers could face the same issues plaguing the Ogallala Aquifer if something is not done. See id .
Dwindling disposal practicality
Drought conditions aren’t the only water problem Texas currently faces. For decades, producers disposed of produced water via deep well injection. See Martha Pskowski & Dylan Baddour, Companies Aim to Release More Treated Oilfield Wastewater into Rivers and Streams , Tex. Tribune (Apr. 29, 2024). Approximately 70% of produced water in the state of Texas is disposed of via deep well injection through saltwater disposal wells (SWD) permitted by the RRC. See Texas Produced Water Consortium, supra, at 16; see also Produced Water Treatment Methods, Atlas Scientific (Nov. 8, 2024). Injection occurs several thousand feet below the groundwater table, where the water will, in theory, not encounter fresh water. See What Is a Saltwater Disposal Well?, Rogue Energy Servs. (July 25, 2022). The produced water is under extreme pressure when injected at deep depths,
Alternative uses of produced water
In the Permian Basin alone, daily water production from horizontal wells is about 1,547 acre-feet. See Texas Produced Water Consortium, supra, at 8. By 2042, it is estimated to increase to 1,935 acre-feet. See id . The current practice is to dispose of this water, but new technology could breathe life into this waste. See id .
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