Texas Intrastate Hydrogen Pipeline Regulations

Recent reports have highlighted Texas's numerous strengths that enable the state to be a leader in hydrogen market development, including accessible low-cost renewable energy and natural gas, a welcoming climate for infrastructure investment and development, and a well-developed industrial sector.¹Additionally, Texas already has an established hydrogen market and the largest hydrogen pipeline network in the United States.²In December 2022, Texas's leadership in the hydrogen market attracted the largest green hydrogen facility in the United States to Wilbarger County, Texas.³

As the Texas hydrogen market grows, hydrogen facility operators will require additional intrastate pipelines to transport hydrogen between production plants, storage facilities, refineries, and customers. The Railroad Commission of Texas ("RRC") has regulatory authority over intrastate hydrogen pipelines in Texas. This article provides an overview of the applicable common-carrier statutes and