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TRC 2-mile Area of Review compliance checklist

A practical checklist for preparing Class II UIC SWD permit applications under the expanded 2-mile AOR rule — what to map, what to pull, what the TRC kicks back as deficient, and how to avoid the usual return letters.

What's inside

  • • Mapping the AOR boundary for vertical and deviated wells
  • • Identifying every artificial penetration (including pre-1982 records)
  • • Confining-zone integrity verification, well by well
  • • Seismic context — SRA overlap, TexNet event queries
  • • Submission package contents the TRC expects
  • • Pre-submission engineering, legal, and notice reviews
  • • Deficiency-letter failure modes we see repeatedly

Why this exists

The TRC expanded the Class II UIC Area of Review from 0.25 miles to 2 miles in mid-2025. The arithmetic: a 2-mile radius covers 64× the area of a quarter-mile radius, which is roughly 64× as many wellbores and plugged penetrations to document. Independent landmen and small operators are the ones feeling it.

We wrote this checklist from patterns we see across public TRC deficiency letters and the workflow used by the landmen we work with. It is a pragmatic working document, not legal advice.

Preparing an actual AOR package right now?

The PermianIQ search pulls every artificial penetration inside a 2-mile radius of any lat/lon or API number, with operator, well status, and spud date. Free to browse — 3 detail views before signup.