ECMC details how operators can generate recycled produced‑water credits under rule 905 c 6 a

ECMC staff explained how operators can generate credits for recycled produced water under the agency's interpretation of rule 905 c 6 a.

"Pursuant to rule 905 c 6 a beginning 01/01/2026, ECMC mandates a minimum of 4% recycled produced water usage or recycled produced water alternatives for well stimulations, recompletions, and restimulations," said Taylor (introduced by the host). Taylor said that requirement applies to well stimulations with OGDPs filed after Jan. 1, 2026 and within the same geologic basin through Dec. 31, 2030. Operators who exceed the minimum may claim recycled produced‑water credits for the volume used above the minimum during the compliance period.

Taylor said operators must submit Form 4 for any location using recycled produced water or alternatives and attach a recycling and reuse plan; ECMC will modify Form 47 to capture fresh water, recycled produced water and recycled produced-water-alternative volumes for drilling and stimulation activities so calculations can be performed. ECMC will allow retroactive approvals for 2026 if plans are submitted prior to Jan. 1, 2027, and clarified that credits may be generated based on when the water is used, not when it was generated.

During Q&A an operator asked whether the guidance should reference Form 2a or clarify cases where recompletions lack OGDPs. Taylor said ECMC will keep the guidance consistent with how the rule is written (which references OGDP filing date), will review the recompletion scenario and will clarify reporting on the revised Form 47 template when it is released.