Relating to the inspection of the location of a proposed Class I injection well.

Contracts

Master Service Agreements (MSAs) with environmental engineering and geoscience firms require immediate amendment.

• Indemnification: You must strengthen indemnification clauses. If TCEQ rejects a virtual inspection report due to poor data quality, the vendor must bear the cost of the subsequent required in-person inspection.
• Scope of Work: Contracts must explicitly require the vendor to produce a certification of "local conditions" and "probable well effects" compliant with Water Code Sections 27.051, 27.055, and 27.056.

Hiring/Training

• Vendor Verification: You do not need new internal staff, but you must verify that your external consultants hold active Texas licenses (P.E. or P.G.). Unlicensed "environmental specialists" are no longer sufficient for this specific reporting requirement.
• Project Management: Train regulatory teams to integrate the "Inspection Report" into the pre-application phase; this is no longer a post-filing step handled by the state.

Reporting & Record-Keeping

• New Filing Requirement: A certified Inspection Report must accompany the permit application.
• Data Archiving: If utilizing virtual inspections, you must archive the specific satellite imagery or aerial data used. This data must be retrievable for audit to prove the imagery was current at the time of the application.

Fees & Costs

• Cost Shift: While state fees do not increase, the applicant now bears the direct cost of the third-party inspection.
• Budgeting: Allocate funds for high-resolution satellite imagery or aerial drone surveys if opting for virtual inspection, as free public sources (e.g., basic Google Earth) may not meet the evidentiary standard for complex sites.