How to Fill Out Texas Railroad Commission Form T-4 (w/Examples) + FAQs

Texas Railroad Commission Form T-4 is the Application for Permit to Operate a Pipeline in Texas, and every pipeline operator that moves oil, gas, or related products through a regulated line must file it with the Railroad Commission of Texas and renew it each year. Without an active T-4 permit, operating a pipeline in Texas is unlawful, and the Commission can assess penalties for running lines with no permit on file.

The form proves that you hold a valid permit, that you have paid your mileage fees, and that the Commission has accurate maps of where your lines run. Get a field wrong, miss your renewal month, or skip a required map, and your application bounces back, which can leave your system operating out of compliance while the clock keeps ticking. The Commission processes thousands of pipeline permit actions every year across the more than 475,000 miles of pipeline it oversees in Texas, so the review staff expects clean, complete filings.

Here is what you will learn in this guide:

• 📋 What Form T-4 is, who must file it, and the rule that requires it
• 🗂️ Every document, number, and map you need before you log in
• 🖥️ A screen-by-screen, field-by-field walkthrough of the online application
• 🧑‍💼 Three real filled-out examples for a new permit, a renewal, and a transfer
• ⚠️ The mistakes that get applications rejected and how to dodge them

What Form T-4 Is and Who Must File It

Form T-4 is the permit application that the Railroad Commission of Texas uses to authorize the operation of a pipeline within the state. The permit is granted under 16 TAC §3.70, the Commission rule titled “Pipeline Permits Required,” and it ties back to the Commission’s broad authority over pipelines in Texas Natural Resources Code §81.051. The permit you receive certifies that you have complied with §3.70 and lists your permit number, the counties you cross, your commodity, your classification, and your total permitted miles.

The rule reaches almost every line that is not a production or flowline. According to the Commission’s permit guide, a T-4 permit is required to operate a pipeline or gathering system unless you operate only production or flowlines, or you fall under a narrow exclusion in §8.1(b)(4). The plain-English takeaway is simple: if you move a regulated commodity across someone else’s land or through a gathering network, you almost certainly need a T-4.

The person who files is the physical operator of the pipeline. The physical operator is the company that actually runs the line day to day, which is not always the same entity that owns the steel or that earns the revenue. The form separates these roles into Pipeline Operator, Pipeline Owner, and Economic Operator so the Commission knows exactly who answers for safety and compliance.

One hard prerequisite controls everything else. Before the online system will let you touch a T-4, your organization must hold a current, active Form P-5 (Organization Report) with the Commission, as required by 16 TAC §3.1. If your P-5 has lapsed, the Pipeline Online Permitting System will not display your operator, and you cannot file. Fix the P-5 first, then return to the T-4.

Before You Start: Documents and Information You Need

Filing goes faster when you gather everything before you log in, because the online system times out and a half-finished application invites errors. The Commission expects a clean package the first time, and missing pieces are the leading reason applications stall in review. Pull these items together before you open the permitting portal.

• Active P-5 number. This is your operator’s registration number with the Commission, and the system checks it before it lets you file. If it is expired, you are locked out.
• RRC Online System login. You need a User ID tied to a Security Administrator. Without filing rights, you cannot submit, only view.
• Existing T-4 permit number (for renewals, amendments, and transfers). This is the number printed on your last permit. Enter the wrong one and you may amend the wrong system.
• Pipeline classification and supporting proof. You must know whether each line is a common carrier, gas utility, or private line, because new applicants must swear to it. The wrong class can trigger eminent-domain questions you cannot answer.
• Commodity type. You report whether the line carries liquid or gas. The Commission groups fees and rules by commodity, so an error here misroutes your application.
• Total mileage, regulated and unregulated. You report permitted miles, regulated miles, and unregulated miles. Mileage drives your fee, so a miscount means you pay the wrong amount.
• Shapefiles and an overview map. New permits, partial transfers, and most amendments require GIS shapefiles plus a PDF overview map per the digital submission standards. Bad geometry gets kicked back by the mapping team.
• Form C-LTR cover letter. Every permit action requires a cover letter that states the application type and mileage. Skip it and the filing is incomplete.
• Form T-4B (for transfers). Both the acquiring and divesting operators must complete and sign this before either submits. A one-sided T-4B halts the transfer.
• Payment method for fees. New permits and renewals carry a processing fee plus a per-mile fee. No payment means no permit.

Where to Get the Form and How to Access It

There is no paper T-4 you mail in for routine permit work. As the Commission’s filing instructions state plainly, all permit work must be completed and submitted online through the Pipeline Online Permitting System (POPS), by the operator or an authorized representative. The companion forms, such as the Form T-4B Pipeline Transfer Certification and the C-LTR cover letter, are fillable PDFs you complete and attach inside POPS.

To reach POPS, you log in through the RRC Online System with a User ID and password. Those credentials come from your company’s Security Administrator. If your organization already files anything electronically with the Commission, such as the Texas Damage Reporting Form, then it already has a Security Administrator who can grant you T-4 filing rights.

If no Security Administrator exists yet, your company must first designate one. You do this by completing the Security Administrator Designation (SAD) form and emailing it to rrconline-security@rrc.texas.gov. Once processed, the Security Administrator receives a User ID and a temporary password, then creates and manages logins for everyone else in the company.

The forms themselves, including sample cover letters, sample overview maps, and sample shapefiles, live on the Commission’s oil and gas forms page and the pipeline mapping pages. Download the current edition every time, because the Commission updates these forms often. The T-4B in use as of this writing is the August 2024 edition, and the cover letter is the January 2024 Form C-LTR, so confirm the revision date printed on each PDF before you fill it in.

Step-by-Step: How to Fill Out Form T-4 Line by Line

POPS organizes a T-4 application into a Dashboard and a series of tabs: Permit, Attachments, Additional Contacts, and Certify/Submit. The walkthrough below follows that order, with one subsection per screen or field group. Use the exact field names shown in the system so your entries land in the right place.

1. The Dashboard

The Dashboard is the first screen you see after logging into POPS. It lists every permit your operator holds, the last filing action on each one, and the date of that action, plus links to the mileage fee payment portal and the button to create a new permit.

To use it, you read the Filing Status and Filing Type columns to confirm where each permit stands before you act. Dana Reyes, a compliance analyst at a gathering company, opens the Dashboard and sees permit 10542 listed with a renewal due in April. From here she clicks the existing permit to renew or amend it, or clicks the create-new option to start a fresh permit and pay the annual fee.

A common edge case is the operator with dozens of permits scattered across renewal months. Sort and read carefully, because the Dashboard shows the month and day of each permit’s expiration, and those do not change from year to year. A frequent mistake is opening the wrong permit number and amending a system you did not mean to touch, which forces a corrective amendment later. The misconception to drop is that the Dashboard “auto-renews” anything; it never does, because nothing happens until you start and submit the filing yourself.

2. Permit Tab: Operator, Owner, and Economic Operator

The Permit Tab asks who is responsible for the pipeline at every level. It shows the Pipeline Operator, the Pipeline Owner, the Economic Operator, and the permit details that apply to the whole permit, with the expiration date in the upper-right corner.

To answer it, confirm that the Pipeline Operator is the physical operator running the line, list the Owner as the entity that holds title to the pipe, and list the Economic Operator as the party that earns the revenue. Flint Hills Resources, LC enters itself as Pipeline Operator, while BATX Pipeline, LLC is listed as the Economic Operator on permit 10542. These three can be the same company or three different companies.

The nuance most filers miss is that the owner and operator are often different entities in midstream deals, and the form expects that split. A common mistake is listing the parent holding company as operator when a subsidiary actually runs the line, which creates a mismatch with the P-5 and stalls review. The misconception to correct is that “owner” and “operator” mean the same thing here; the Commission treats them as separate roles because compliance responsibility follows the physical operator, not the title holder.

3. Permit Tab: Commodity Transported

This field asks what the pipeline carries, recorded as either Liquid or Gas. The entry controls which fee schedule and which regulatory program apply to your line.

To answer it, select the single commodity that matches the product in the line. On permit 10542, Flint Hills enters Commodity transported: Liquid because the line moves refined products. If you operate both gas and liquid systems, you file separate permits, because one permit covers one commodity type.

The edge case here is a line that changes service, such as a switch from crude to refined product, which is handled later through an amendment with a Fluid Change (FC) code, not by editing this box on a whim. A common mistake is choosing gas for a line carrying liquid hydrocarbons, which misroutes the application and produces the wrong fee. The misconception to drop is that commodity and classification are the same thing; commodity is what flows, while classification is your legal status as a carrier.

4. Permit Tab: Pipeline Classification

This field asks for your legal status as a carrier, chosen from Common Carrier, Gas Utility, or Private Line. Classification matters because a common carrier or gas utility may hold the power of eminent domain, while a private line does not.

To answer it, select the class that matches how your line operates and, for a new permit, back it up. Under the pipeline permit rule, new applicants must submit a sworn statement and documentation supporting a common-carrier claim, a requirement the Commission added in 2015 after court decisions tightened what counts as a common carrier. A new crude line that hauls product for unaffiliated shippers checks Common Carrier and attaches a sworn T-4A specification sheet and shipper documentation.

The plain-English point about §3.70 is that it forces you to prove, not just assert, your carrier status. The consequence of ignoring it is real: an unsupported common-carrier claim can be challenged, and the eminent-domain power you assumed may not hold up. A short scenario shows why it matters: a private gathering line that serves only its own affiliate cannot claim common-carrier status just to use condemnation, and doing so invites a legal fight. The misconception to correct is that checking “common carrier” automatically grants eminent domain; it does not, because the sworn proof and the underlying facts control.

5. Permit Tab: Counties and Mileage

This field group asks where your line runs and how long it is, captured as the counties crossed plus Total Permitted Miles, Regulated Miles, and Unregulated Miles. Mileage drives your annual fee, so accuracy here protects your wallet and your compliance status.

To answer it, list every county the pipeline touches and enter mileage to the hundredth of a mile. On permit 10542, Flint Hills enters BASTROP, TRAVIS, with Total Permitted Miles 17.50, Regulated Miles 17.50, and Unregulated Miles 0.00. These numbers must match the mileage in your shapefiles and on your overview map.

The edge case is a line that crosses into a county you forgot, which the mapping team catches when your shapefile geometry does not match your county list. A common mistake is rounding miles or pulling the figure from an old as-built rather than the current GIS, which creates a mismatch that bounces the filing. The misconception to drop is that unregulated miles are “free” to leave off; you still report them so the Commission has a complete picture, and you mark them through the proper attribute (TX_REG = N) in the shapefile.

6. Attachments Tab: Cover Letter (Form C-LTR)

This tab is where you attach your documents, starting with the Form C-LTR POPS Cover Letter that every permit action requires. The cover letter tells the reviewer what kind of application this is and what mileage is changing.

To complete it, fill in the Operator Information block (Operator Name, Operator Agent Name, P-5 Number, T-4 Permit Number, Date), answer whether eminent domain was ever declared for this permit, and check the Application Type: Renewal, New Permit, Inactivate, or Amendment/Transfer. Merle Teeter of Flint Hills Resources enters P-5 Number 273881, T-4 Permit Number 10542, dates it, and checks New Permit, then enters Total Active New Permit Mileage 17.50. You fill out only the section that matches your application type, because the form hides the others.

The nuance is the eminent-domain question, which is required and feeds the Commission’s landowner-protection tracking tied to the Texas Landowner’s Bill of Rights. A common mistake is leaving that yes/no blank, which makes the cover letter incomplete and stops review. The misconception to correct is that the cover letter is optional boilerplate; it is mandatory for every action, including a simple renewal.

7. Attachments Tab: Overview Map and Shapefiles

This field set asks for the maps that show exactly where your line sits, made up of a PDF overview map and, for most actions, GIS shapefiles. The Commission’s mapping team checks these against your reported mileage and counties.

To answer it, attach an overview map for every action, and attach shapefiles whenever they are required. Per the permit submission guide, renewals and total transfers need only a simple overview map, while new permits, partial transfers, and other amendments need both an overview map and shapefiles built to the digital submission standards. For the new Bastrop-to-airport line, the mapping contact attaches shapefiles and an overview map showing 17.5 miles across Bastrop and Travis counties.

The nuance is the T4_AMD attribute inside the shapefile, which must carry the right two-letter code (such as PA for Pipeline Addition or FT for Full Transfer) so the geometry matches your cover letter. A common mistake is submitting shapefiles whose mileage or codes disagree with the cover letter, which the mapping team rejects on sight. The misconception to drop is that a renewal needs fresh shapefiles; it usually does not, because a renewal does not change your line, only the permit year.

8. Additional Contacts Tab

This tab asks who the Commission should talk to about the permit, listing the compliance rep, the filing rep, and the mapping contact. Both the compliance rep and the filing rep receive every notice the Commission sends.

To complete it, enter current names, phone numbers, and emails for each role, and update them whenever staff change. Flint Hills lists its GIS contact, Larissa Howard, as the mapping contact with her direct phone and email. You can edit these contacts at any time except after the permit has been submitted for review.

The nuance is that notices, including deadline reminders and deficiency letters, go to the listed reps, so a stale email means you miss warnings. A common mistake is leaving a departed employee as the compliance rep, which sends your renewal reminders into an inbox nobody reads. The misconception to correct is that one contact covers everything; the Commission wants all three roles filled so mapping questions and compliance notices reach the right people.

9. Certify/Submit Tab

This final tab is where you swear the application is true and send it in. You agree to the Operator Certification before submitting, and for renewals you are routed to the payment portal for that year’s fee.

To complete it, read the certification, which mirrors the sworn language under Texas Natural Resources Code §91.143 that you are authorized to file and that the application is accurate, then submit. After paying the renewal fee in the portal, Dana Reyes clicks Certify and Submit, and POPS updates permit 10542 to a new expiration year. Filing a false certification carries penalties under that statute, so confirm every figure first.

The nuance for renewals is timing: a permit whose expiration is more than six months away cannot be renewed yet, and a permit within one month of its renewal date should be renewed before you start any other process. A common mistake is starting an amendment on a permit that is days from expiring, which can tangle the filing; renew first, then amend. The misconception to drop is that submitting equals approval; submission only sends the package to Commission review, where staff can still return it for fixes.

Three Filled-Out Examples Using Real Scenarios

The tables below walk three named filers through the most common T-4 situations. Each shows what the filer enters in the major fields.

Scenario A: New common-carrier permit (Marcus Bell, regulatory manager for a new crude line)

Form Section	What Marcus Enters
Application Type (C-LTR)	New Permit
Pipeline Operator	Lone Star Crude Transport, LLC
Pipeline Owner	Lone Star Crude Transport, LLC
Economic Operator	Lone Star Midstream Holdings, LLC
Commodity Transported	Liquid
Classification	Common Carrier (with sworn T-4A and shipper proof)
Counties	KARNES, DEWITT
Total New Permit Mileage	22.40
Eminent domain ever declared?	No
Attachments	Cover letter, overview map, shapefiles (PA code)

Scenario B: Annual renewal (Dana Reyes, compliance analyst for a gathering system)

Form Section	What Dana Enters
Application Type (C-LTR)	Renewal
T-4 Permit Number	10542
P-5 Number	273881
Total Active Mileage Being Renewed	17.50
Commodity Transported	Liquid
Counties	BASTROP, TRAVIS
Eminent domain ever declared?	No
Attachments	Cover letter and simple overview map (no shapefiles)
Certify/Submit	Agrees to certification, pays renewal fee
Result	Expiration year advances; month and day stay the same

Scenario C: Total transfer (Priya Shah for the acquiring operator; Tom Nguyen for the divesting operator)

Form Section	What the Operators Enter
Application Type (C-LTR)	Amendment / Transfer
Form T-4B required?	Yes, both sections completed and signed
Total transfer?	Yes (selection matches on both halves)
Permit Number transferred	10542 (must match on both sides)
Effective Date of Transfer	06/15/2026 (must match on both sides)
Acquiring choice	Keep original permit number
Divesting eminent-domain question	Answered (required)
Shapefiles	FT code (none needed for a total transfer except Transfer Merge)
Attachments	Cover letter, overview map, fully signed T-4B
Notification timing	Filed within 30 days of the transfer

How to File the Completed Form

There is one filing channel for the T-4 application itself, and it is online. As the Commission’s instructions make clear, all permit work is submitted through POPS inside the RRC Online System; there is no mail-in or fax option for the permit application. The companion PDFs (C-LTR and T-4B) are attached inside POPS rather than sent separately.

• Portal (POPS): Log in at the RRC Online System login page, complete the tabs, attach your documents, and submit. Keep your confirmation and the submitted PDF package as proof of filing.
• Fees: New permits and renewals carry a permit processing fee plus a per-mile mileage fee, both set out on the pipeline fees page. Amendments carry no fee unless they create a new permit.
• Payment method: You pay through the mileage fee payment portal linked on your Dashboard at the time you create or renew a permit. Renewals route you to the payment portal on the Certify/Submit step.
• Processing time: Times vary with volume and the complexity of your maps, so file your renewal early in your renewal month rather than on the last day.
• Proof of filing: Save the POPS confirmation, the payment trace number, and the final permit PDF the Commission issues, which lists your permit number, miles, classification, and validity date.

For questions during filing, the Pipeline Permitting Section can be reached at 512-463-7058 or pops@rrc.texas.gov. Keep that contact handy, because a quick call often resolves a stuck application faster than resubmitting.

What Happens After You File

Once you submit, your application moves into Commission review, where permitting and mapping staff check your cover letter, maps, mileage, and fees against the rule. If everything matches, the Commission issues a Permit to Operate a Pipeline in Texas that certifies compliance with 16 TAC §3.70 and lists your permit number, commodity, classification, counties, permitted miles, and a “valid until” date.

If something is off, the filing reps listed on your Additional Contacts tab receive a deficiency notice. Common reasons for a return include shapefile geometry that does not match the reported mileage, a missing cover-letter section, or an unanswered eminent-domain question. You fix the issue and resubmit through POPS.

Your permit then sits on a yearly cycle. The expiration month and day stay fixed, and only the year advances when you renew. Amendments you file during the year, such as adding miles or changing fluid, update your maps and mileage but do not push out the expiration date, so you still must renew on schedule.

The practical reminder is to watch your renewal month closely. Renew within your designated month under §3.70(j)(2), because operating on a lapsed permit can draw penalties and late fees documented on the pipeline fees page.

Mistakes to Avoid When Filling Out the Form

Each error below has a direct consequence, and most lead to a returned application or a compliance gap.

• Filing with a lapsed P-5: the system will not show your operator, so you cannot file at all.
• Opening the wrong permit number on the Dashboard: you amend a system you did not intend to change and must file a correction.
• Listing the owner as the operator: the mismatch with your P-5 stalls review until you correct the roles.
• Choosing the wrong commodity: the filing routes to the wrong program and produces the wrong fee.
• Claiming common carrier without proof: the unsupported classification can be challenged and your eminent-domain power questioned.
• Misreporting mileage: a miscount means you pay the wrong fee and your maps will not reconcile.
• Submitting shapefiles that disagree with the cover letter: the mapping team rejects the package outright.
• Using the wrong T4_AMD code in the shapefile: the change type does not match your stated action and the filing bounces.
• Leaving the eminent-domain question blank on the C-LTR: the cover letter is incomplete and review halts.
• Submitting a one-sided Form T-4B: a transfer needs both operators’ sections signed, or it cannot proceed.
• Starting an amendment when a renewal is due within a month: the timing tangles your filing, so renew first.
• Letting a departed employee stay as the listed rep: deadline and deficiency notices go unread and you miss your renewal.

Do’s and Don’ts

Do:

• Confirm your P-5 is active before you log in, because nothing works without it.
• Gather mileage, classification, and maps first, since the portal can time out mid-filing.
• Match your shapefile mileage, county list, and cover letter exactly, because the mapping team cross-checks them.
• Renew within your designated month, since the expiration day never moves and lateness draws fees.
• Save your confirmation, payment trace number, and final permit PDF as proof of filing.
• Keep all three contacts current, so every notice reaches a live inbox.

Don’t:

• Don’t assume an amendment renews your permit, because only a renewal changes the year.
• Don’t claim common carrier without the sworn statement and supporting documents.
• Don’t round or estimate mileage, since fees and maps depend on the exact figure.
• Don’t submit a transfer with only one side of Form T-4B completed.
• Don’t wait until the last day of your renewal month, because review takes time.
• Don’t leave the eminent-domain question blank, since it is required on every cover letter.

Pros and Cons of Filing on Your Own vs. With Help

Operators can file in-house or hire a permitting and GIS consultant, and the right choice depends on your staff and the complexity of your systems.

Pros of filing in-house:

• You save the consultant fee, which adds up across many permits.
• Your own staff know your systems and mileage best.
• You control the timing and can renew the moment your month opens.
• You build internal expertise that pays off year after year.
• You keep sensitive route and shipper data inside the company.

Cons of filing in-house:

• You need GIS skill to build compliant shapefiles, which not every operator has.
• A misread of §3.70 can lead to a wrong classification or a returned filing.
• Staff turnover can leave nobody who knows the POPS process.
• Mapping errors cost you time in back-and-forth with the Commission.
• One missed renewal month can put you out of compliance and into penalties.

FAQs

Do I have to file Form T-4 online?

Yes. All T-4 permit work must be submitted through the Pipeline Online Permitting System (POPS) in the RRC Online System. There is no mail-in or fax option for the permit application itself.

Do I need an active P-5 before I can file a T-4?

Yes. The system only accepts permit work from operators with a current Form P-5 (Organization Report). If your P-5 has lapsed, fix it before you attempt the T-4.

Does amending my permit also renew it?

No. Amendments report changes to your system but do not renew the permit or move the expiration date. You still must file a separate renewal in your designated month.

Do I write the Pipeline Operator and Pipeline Owner as the same entity?

No. They are separate fields on purpose. List the physical operator as Operator and the title holder as Owner, even when a third entity is the Economic Operator.

Do I select “Liquid” or “Gas” in the Commodity Transported field?

No single rule fits all; you choose the one commodity your line carries. If you run both gas and liquid systems, you file separate permits because one permit covers one commodity.

Do I have to answer the eminent-domain question on the cover letter?

Yes. The eminent-domain yes/no on Form C-LTR is required for every application type. Leaving it blank makes the cover letter incomplete and stops review.

Do I need shapefiles for a renewal?

No. Renewals and total transfers need only a simple overview map. New permits, partial transfers, and most other amendments require both shapefiles and an overview map.

Do both operators have to sign Form T-4B for a transfer?

Yes. Both the acquiring and the divesting operator must complete and sign their sections, and the permit number and effective date must match on both halves before either submits.

Do I have to prove my common-carrier status?

Yes. New applicants claiming common carrier must submit a sworn statement and supporting documentation under 16 TAC §3.70, a requirement added after court rulings tightened the definition.

Do I report unregulated miles, or just regulated ones?

Yes, report both. You enter Total Permitted Miles, Regulated Miles, and Unregulated Miles, and you flag unregulated segments in the shapefile (TX_REG = N) so the Commission has the full picture.

Does my permit expiration month change when I renew?

No. The month and day stay fixed, and only the year advances. A permit more than six months from expiring cannot be renewed yet.

Do I owe a fee for an amendment?

No, not usually. Amendments carry no fee unless they create a new permit. New permits and renewals do carry a processing fee plus a per-mile mileage fee.

Do I have to file a transfer notification by a deadline?

Yes. The operator must file a notification of transfer with the Commission within 30 days of the transfer, or risk a penalty for operating without a permit.

Do I keep proof after I submit?

Yes. Save your POPS confirmation, the payment trace number, and the final permit PDF. These show your permit number, miles, classification, and validity date if a question ever arises.