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From the Executive Summary:

In Texas, flaring is governed by both the Texas Railroad Commission (RRC) and the Texas Commission on Environmental Quality (TCEQ). Permits for flaring are governed by Rule 32, which makes flaring illegal except under specific circumstances. When an operator wishes to flare they are legally required to apply for a flaring permit (a Rule 32 Exception) from the RRC. Those permits have increased 65 fold in the past 11 years.1 

In this report, Earthworks compares RRC’s flare permitting database against 227 flares directly observed and recorded during helicopter flyovers with optical gas imaging cameras. 69-84% of observed flares did not have required flaring permits (Rule 32 exceptions). 

Shell and Exxon, both of which have made prominent climate commitments and called for stronger federal oversight of oil and gas air pollution, were among the violators: Shell did not have a permit for any of its observed flares; Exxon only had permits for two flares. 

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