Railroad Commission v. Texas Citizens for a Safe Future & Clean Water, 336 S.W.3d 619

Barnett Shale wells require fracturing; produced oil/gas waste disposed via underground injection wells; Pioneer applied for a permit to convert an existing well to an oil/gas waste injection well.
Texas Citizens for a Safe Future and James Popp opposed the permit, raising traffic-safety and road-impact concerns.
Hearing examiners recommended granting the permit, finding disposal would increase production and public interest; Commission adopted those findings.
Court of Appeals reversed, holding the Commission abused its discretion by narrowly interpreting public interest as production-related only and remanded to reconsider with broader factors including traffic safety.
Legislative scheme distinguishes Commission (oil/gas waste) from TCEQ (industrial/municipal waste) and contemplates traffic-safety considerations for TCEQ, not the Commission; the Legislature amended the statute to require traffic considerations for TCEQ but not for the Commission.
Supreme Court held the Commission’s interpretation of “public interest” as a narrow, production-focused inquiry is reasonable and entitled to deference; Court reversed the Court of Appeals and rendered for Commission and Pioneer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commission’s interpretation of ‘public interest’ is entitled to deference.	Texas Citizens argues ‘public interest’ is broad and open-ended.	Commission argues ‘public interest’ is narrow and limited to oil/gas production and resource protection.	Yes; the Commission’s interpretation is reasonable and entitled to deference.
Whether traffic-safety factors may be considered by the Commission under public interest.	Texas Citizens contends traffic safety should be weighed as part of public interest.	Traffic safety is not within the Commission’s public interest scope; TCEQ handles such factors.	No; traffic-safety factors are not part of the Commission’s public-interest inquiry.
Whether deference to agency interpretation is appropriate given the statutory scheme.	Burnishes that deference should be limited or rejected where statute is clear.	Agency has expertise; deference appropriate if interpretation is reasonable and consistent with statute.	Yes; deference appropriate under the statutory framework and agency expertise.

Fiess v. State Farm Lloyds, 202 S.W.3d 744 (Tex. 2006) (agency construction of ambiguous statute given deference if reasonable)
First Am. Title Ins. Co. v. Combs, 258 S.W.3d 627 (Tex. 2008) (serious consideration given to agency interpretation; defer if reasonable)
Pub. Util. Comm’n v. City Pub. Serv. Bd. of San Antonio, 53 S.W.3d 310 (Tex. 2001) (longstanding deference to agency construction in regulatory context)
Dodd v. Meno, 870 S.W.2d 4 (Tex. 1994) (statutory interpretation with agency perspective given weight)