Oil and gas permitting: a U.S. onshore compliance checklist

Start with the land and the operation

Record the surface parcel, mineral estate, well trajectory, pad boundary, access route, gathering connection, and disposal destination on one controlled map. BLM's split-estate guidance explains why private surface ownership does not establish that the underlying minerals are private. A directional well can encounter federal minerals even when its pad sits on entirely nonfederal land.Bureau of Land Management ↗Bureau of Land Management ↗

Make unresolved jurisdiction a named task. “Private land” and “existing location” are descriptions, not documented exemptions. For a reused pad, compare the proposed operation with the actual permits and their conditions; the last operator's permit list is only a starting point.

Build one source package before filing

Land, drilling, environmental, and facilities teams should work from the same revision. At minimum, assemble the legal operator name, coordinates, well identifiers, site plan, process description, equipment list, production assumptions, gas analysis, water balance, and construction sequence. Give every assumption an owner and a date. Record whether a number is measured, vendor-supplied, calculated, or preliminary.

An illustrative change shows why this matters: facilities engineering adds a compressor after the air consultant freezes the emissions calculation. The drilling application remains unchanged, but the air basis may no longer describe the proposed site. A shared change log makes that discrepancy visible before equipment arrives. Keep an explicit list of items that cannot be finalized until vendors or surveyors deliver their inputs.

Separate operator eligibility from permission to drill

For federal leases, BLM processes the application for permit to drill, or APD, with environmental and resource reviews. Its permitting guidance identifies NEPA, historic-preservation, and endangered-species requirements, and explains that site-specific conditions may accompany approval. Build those conditions into the work package. Do not interpret an approved APD as permission to disregard its surface restrictions.Bureau of Land Management ↗

State requirements still need their own review. In Texas, organizations conducting operations within RRC jurisdiction must maintain a current P-5 Organization Report. RRC's procedure manual separately identifies financial assurance, drilling forms, completion reports, groundwater protection, and production reporting. The operator record and the individual well application serve different purposes.Railroad Commission of Texas ↗Railroad Commission of Texas ↗

In New Mexico, use OCD's current operator guidance to identify the applicable forms and instructions for the proposed activity. Its guidance covers groundwater, environmental permitting, produced-water reuse, and natural-gas management. Do not transplant a Texas filing sequence into a New Mexico project.New Mexico Energy, Minerals and Natural Resources Department ↗

Resolve the air basis while equipment is still changeable

Prepare the air review around the full proposed operation: tanks, loading, engines, compressors, dehydration, controls, and startup or maintenance activities. In Texas, the oil-and-gas permit-by-rule pathway requires the facility to satisfy both general and specific conditions. TCEQ also identifies standard-permit and individual NSR options. A small facility is not automatically eligible for the simplest pathway.Texas Commission on Environmental Quality ↗

Distinguish authorization to construct or modify an emissions source from an operating-permit obligation. TCEQ lists New Source Review and Title V operating permits as separate programs. Add applicable federal equipment standards to the same register, but preserve their separate legal bases. A state permit does not make the federal applicability analysis unnecessary.Texas Commission on Environmental Quality ↗Texas Commission on Environmental Quality ↗

Record the limits that drive the chosen route, along with the calculations and representative analyses supporting them. Before procurement is released, compare the selected equipment with those assumptions. An engine substitution, different operating hours, or revised tank throughput should reach the environmental owner while there is still time to change the package.

Treat water as four decisions

First, document the source of construction and completion water, contractual availability, and any applicable water-right or withdrawal authorization. Second, decide how runoff will be managed. Third, establish where produced water and other wastewater will go. Fourth, assess crossings and placement of fill. A disposal contract answers only one part of that review.

The federal oil-and-gas stormwater exemption is conditional. EPA describes protection for qualifying runoff that is not contaminated by contact with specified materials or wastes, and identifies circumstances that trigger permit coverage, including certain reportable discharges and water-quality violations. Its guidance expressly says the exemption does not cover Section 404 permits. Avoid the blanket claims “all pads need a construction stormwater permit” and “oil and gas is exempt.”U.S. Environmental Protection Agency ↗

For work involving dredged or fill material in jurisdictional waters, including wetlands, evaluate Section 404 authorization before the discharge occurs. Review the current jurisdictional determination and permit conditions for the actual crossing or footprint.U.S. Environmental Protection Agency ↗

For wastewater, establish the applicable Part 435 subcategory and disposal pathway. EPA's extraction guidelines distinguish onshore, coastal, offshore, agricultural and wildlife use, and stripper-well categories. Underground disposal has a different framework: Class II covers specified oil-and-gas-related injection activities, administered through the responsible UIC program. Do not treat a production-well approval as an injection authorization.U.S. Environmental Protection Agency ↗U.S. Environmental Protection Agency ↗

Screen SPCC applicability using the facility's oil-storage configuration and discharge potential. Where a plan is required, connect the plan's containment, inspection, and response provisions to the constructed site. Check that a contractor's drawings have not removed the drainage controls the plan relies on.U.S. Environmental Protection Agency ↗

Include the gathering connection and field safety

A gathering line needs its own classification. PHMSA's onshore gas-gathering framework distinguishes line categories and extends reporting to previously unregulated gathering lines, while applying safety requirements according to classification. Record the pipeline operator, system boundary, and responsible regulator. The production permit is not a substitute for that analysis.Pipeline and Hazardous Materials Safety Administration ↗

Run worker-safety preparation alongside permitting. OSHA identifies hydrocarbon vapors, hydrogen sulfide, silica, noise, and other extraction hazards. Assign the site-specific assessment, contractor coordination, training, and emergency arrangements to competent safety personnel. An environmental approval does not establish that crews are ready to mobilize.Occupational Safety and Health Administration ↗

Release activities against evidence, not a percentage complete

Use a short release sheet for each activity. The rows below are project controls to adapt to the permit register, not a universal list of statutory approvals.

For every open row, show the missing evidence, person responsible, latest acceptable date, and work that must wait. “Submitted” should remain different from “approved.” An approval with outstanding pre-start conditions should remain different from an unconditional release.

Hand over the conditions with the asset

Before first production, turn each recurring condition into an assigned task with its frequency, trigger, required record, and reporting destination. Preserve submission receipts and the version actually filed. Keep a calendar for expirations and renewals where applicable. After startup, reassess equipment changes, ownership transfers, new waste routes, and changes in throughput against the existing approvals.

The useful outcome is a clear answer to a field question: can this team perform this activity on this site today, and which document supports that decision? If the answer requires reconstructing the project from five inboxes, the permit register is not finished.