Tex. Codes » Natural Resources Code · TITLE 3. OIL AND GAS · SUBTITLE B. CONSERVATION AND REGULATION OF OIL AND GAS · CHAPTER 85. CONSERVATION OF OIL AND GAS
Texas Codes

Tex. Nat. Res. Code § 85.045 (2026)

Waste Illegal And Prohibited

✓ current as of May 2026
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Sec. 85.045. WASTE ILLEGAL AND PROHIBITED. The production, storage, or transportation of oil or gas in a manner, in an amount, or under conditions that constitute waste is unlawful and is prohibited.

Acts 1977, 65th Leg., p. 2517, ch. 871, art. I, Sec. 1, eff. Sept. 1, 1977.

Notes of Decisions
Cited in 7 cases, 2005–2019 · leading case: Coastal Oil & Gas Corp. v. Garza Energy Trust, 268 S.W.3d 1 (Tex. 2008).
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Coastal Oil & Gas Corp. v. Garza Energy Trust, 268 S.W.3d 1 (Tex. 2008). · cites it 4× “TEX. NAT. RES. CODE §§ 85.045, 86.011. Waste includes "physical waste or loss incident to or resulting from drilling, equipping, locating, spacing, or operating a well or wells in a manner that reduces or tends to reduce the total ultimate recovery of oil or gas from any pool.”
Lightning Oil Co. v. Anadarko E&P Onshore, LLC, 520 S.W.3d 39 (Tex. 2017). “”); Tex. Nat. Res. Code § 85.045; West, 508 S.”
Exxon Corp. v. Miesch, 180 S.W.3d 299 (Tex. App. 2005). · cites it 5× “16, § 59 (stating that “the preservation and conservation of all such natural resources of the State are each and all hereby declared public rights and duties; and the Legislature shall pass all such laws as may be appropriate thereto”). Exxon next argues that the natural…”
Discovery Operating, Inc. v. BP Am. Prod. Co., 311 S.W.3d 140 (Tex. App. 2010). “See Tex. Nat. Res.Code Ann. §§ 85.045, 85.046 (Vernon 2001).”
Key Operating & Equip., Inc. v. Will Hegar & Loree Hegar, 435 S.W.3d 794 (Tex. 2014). “1962); see also Tex. Nat. Res.Code § 85.045. Pooling is one method to prevent waste.”
Cimarex Energy Co. v. Anadarko Petroleum Corp., 574 S.W.3d 73 (Tex. App. 2019). “See generally TEX. NAT. RES. CODE ANN. §§ 85.045, 85.048, 85.”
Ring Energy v. Trey Res., Inc., 546 S.W.3d 199 (Tex. App. 2017). “Waste is declared unlawful and is prohibited under TEX.NAT.RES.CODE ANN. § 85.045. "Waste" specifically includes "drowning with water a stratum or part of a stratum that is capable of producing oil or gas or both in paying quantities.”
— Tex. Nat. Res. Code § 85.045(3) — 1 case
Exxon Corp. v. Miesch, 180 S.W.3d 299 (Tex. App. 2005). “16, § 59 (stating that “the preservation and conservation of all such natural resources of the State are each and all hereby declared public rights and duties; and the Legislature shall pass all such laws as may be appropriate thereto”). Exxon next argues that the natural…”
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