FERC’s July Commission Meeting: NERC’s Data Center Reliability Deadline
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How to Track a Texas Gas Storage Project That FERC Never Sees
Originally published for customers July 24, 2026.
What’s the issue?
United States gas storage capacity has stayed almost flat over the last decade even as LNG exports and gas production have surged. Storage projects draw far less public attention than pipelines and offer fewer visible milestones, which makes them hard to track and their progress hard to confirm.
Why does it matter?
Each new storage project carries outsized importance as the cushion in the gas market keeps shrinking. FERC dockets offer some visibility into interstate storage, but intrastate projects often have no public visibility at all outside of limited state filings.
What’s our view?
Tracking permits through the Texas Railroad Commission, particularly Form P-5 and the H-4/H-1 storage permits, gives a reliable, independent way to confirm a project’s scope and its progress toward in-service when the physical milestones a pipeline offers simply aren’t there.
U.S. LNG feedgas demand is on pace to double to 36 Bcf/d within five years, according to a recent S&P Global study, and Arbo is tracking roughly 37 Bcf/d of pipeline capacity additions by the end of 2027. Storage has not kept pace: national design capacity has actually declined slightly since 2016, from 4,688 Bcf to 4,683 Bcf in 2025. That gap makes every new project matter more, and most storage development, like most planned pipeline additions, is concentrated in the Gulf, particularly Texas and Louisiana. This post breaks down how to track Texas gas storage projects through the Railroad Commission’s permitting record when FERC oversight doesn’t apply.
Why Gas Storage Is Harder to Track Than Pipelines
Exports have more than doubled in five years, from 6.5 Bcf/d in 2020 to 15.1 Bcf/d in 2025, and marketed production is up 18% over the same period. The result is a tighter market with less flexibility to absorb peak summer and winter demand swings, exactly the volatility storage is meant to cushion. This is far from just an LNG problem. With data center-driven demand growth on the horizon, the days of storage cover available to the market will keep shrinking without change; ERCOT forecasts Texas power demand will grow to four times its current all-time peak by 2032, a jump that only adds to the need for storage that can handle intermittent demand. As we noted when Chairman Christie departed FERC amid rising grid stress, gas storage has lagged well behind production growth.
Storage projects are simply harder to see than pipelines. Pipelines have compressor stations and routes with mileage that can be checked against maps; a storage facility’s progress is hard to observe from the outside until it’s finished. Interstate storage facilities regulated by FERC leave a clear paper trail through each permitting milestone, from the initial application and environmental review through the certificate, the authorization to begin construction, and periodic construction reports. Pipelines under FERC review offer the same kind of visible trail, as seen in two western gas pipeline permitting cases at FERC. Intrastate gas storage has no such backstop: there are no federal filings to track, and public information on permitting status is sparse to nonexistent.
To address that gap, we looked at every greenfield natural gas storage project in Texas placed into service since 2005. Despite two decades of activity, the list is short: four projects already in service (Golden Triangle Storage, Tres Palacios, Waha Gas Storage, and Trinity Gas Storage) and two under development (Nash Energy Storage Hub and TRU Hub). Of the four in service, Golden Triangle Storage and Tres Palacios are FERC-regulated, while Trinity Gas Storage and Waha Gas Storage are not. Every project on the list, in service or in development, has either added a brownfield expansion or announced one, Nash and TRU Hub included, underscoring how much of the industry’s storage growth still runs through existing facilities rather than new ones.
How to Track Texas Gas Storage Through the Railroad Commission
Whether a project is interstate or intrastate, all storage facilities in Texas must receive permits from both the Texas Railroad Commission (TRRC) and the Texas Commission on Environmental Quality before construction can begin. Because neither greenfield project under development has started construction, these permits are the most relevant milestones available to track. Our research focused on the TRRC side, since developers have referenced these authorizations in recent announcements.
From Form P-5 to the H-4/H-1 Permit
The first step for any operator is Form P-5, required of any entity operating within the jurisdiction of the TRRC’s Oil and Gas Division. It is essentially company registration: a small filing fee and annual renewal with no substantive review. It is also a useful filter. A project without a Form P-5 is just a proposal.
The next milestone is one of two project-specific applications: Form H-4 for salt-dome storage under Statewide Rule 97, or Form H-1 for depleted-reservoir storage under Statewide Rule 96. Both require substantial project detail, including well counts, location, field name, and cavern specifications, which lets us confirm or refine a project’s scope independent of what a developer says in other public-facing communications.
When the Neighbors Object
Filing the H-4 or H-1 triggers a notice requirement: nearby landowners, local government officials, and the public, via three consecutive weeks of newspaper notice, all have the opportunity to protest. A protest sends the application to the TRRC’s Hearings Division for a formal hearing.
Waha Gas Storage illustrates the process. The volume of fresh water needed to leach the underground caverns, a process that dissolves salt to create storage space and pumps out the resulting brine, drew concerns from the Town of Pecos City over its municipal water supply. The case proceeded to a scheduled hearing where both sides presented evidence, followed by a final Commission order. Waha was ultimately approved, but its H-4 permit did not arrive until about one year after the original application and seven months after the hearing.
The timeline covers only Rule 97-compliant (salt cavern) projects, which Trinity Gas Storage is not. It also doesn’t capture how much construction timelines vary once a project clears the permit. Greenfield salt cavern storage typically takes several years to build, since leaching is by far the most time-consuming part of the job. Tres Palacios is the exception that proves the rule: it started construction early, and its Cavern 1 was placed in service in under a year because it repurposed caverns within the Markham Salt Dome that had already been leached through prior commercial brine production.
Permits in Hand, Progress on Hold
The four in-service projects, whether FERC-regulated (Golden Triangle, Tres Palacios) or not (Trinity Gas Storage, Waha Gas Storage), began construction relatively soon after securing their H-4 permits (H-1 for Trinity). The two projects still in development have not started construction despite holding the permit for more than a year. Financing and customer commitments appear to be the gating factor. TRU Hub has said as much on its own website, and Nash Energy Storage Hub only secured an equity commitment in April 2026 and plans to launch a non-binding open season in September 2026 before a final investment decision in Q1 2027.
It’s tempting to read that gap as a shift in how greenfield storage gets financed, but with only two data points it’s too early to call it a trend. Trinity Gas Storage didn’t file with the TRRC until after financing was already in place, the reverse of what Nash and TRU Hub are doing. TRU Hub’s own timeline has a plausible explanation: the project shifted its focus from hydrogen storage to mostly natural gas storage, a change that would reasonably reset some of the financing runway. Regardless of approach, greenfield storage is a long, capital-intensive build, but it carries real advantages once it clears that hurdle:
Strategic siting near demand centers like LNG terminals, an option that mattered far less decades ago when most existing fields were developed. Storage built alongside new Gulf Coast export capacity, such as Venture Global’s Plaquemines expansion, can match feedgas needs directly.
Modern, high-turn design built for rapid-cycle deliverability, matching the fast injection and withdrawal swings LNG terminals need during feedgas upsets, rather than retrofitting aging seasonal-cycle infrastructure.
A higher capacity ceiling, with the potential to relieve undersupplied regions.
Why the TRRC Timeline Is the Best Way to Track Storage
As more storage capacity gets built, particularly intrastate projects, the TRRC’s regulatory timeline will be the most reliable way to track concrete progress in Texas rather than relying on developer statements alone. Waha Gas Storage proved the point directly: with no FERC oversight at all, the TRRC hearings record was the only substantive source on the project’s status. Storage will likely never draw the public and analyst attention pipelines do, and it will never offer the same visible physical progress markers. FERC’s docket, where it applies, closes only part of the gap. Arbo will continue building out its coverage of gas storage, distinguishing projects actually on a path to in-service from those that remain market chatter. Given how much infrastructure and storage capacity is concentrated in Texas and Louisiana, understanding the state and local regulatory process will be essential to tracking what comes next.
Frequently Asked Questions
Does FERC regulate Texas gas storage projects?
Only interstate storage facilities fall under FERC jurisdiction. Intrastate Texas gas storage projects are regulated by the Texas Railroad Commission and the Texas Commission on Environmental Quality, not FERC, so they leave no federal paper trail.
What permits does a Texas gas storage project need from the Railroad Commission?
An operator first files Form P-5 to register with the TRRC’s Oil and Gas Division, then files Form H-4 for salt-dome storage under Statewide Rule 97 or Form H-1 for depleted-reservoir storage under Statewide Rule 96.
How long does TRRC storage permitting take?
It varies. Waha Gas Storage received its H-4 permit about one year after applying and seven months after its hearing, in part because a landowner protest sent the application to a formal hearing.
Why is gas storage harder to track than pipelines?
Storage projects offer fewer visible milestones than pipelines, and intrastate projects file nothing with FERC, so state permitting records are often the only public window into whether a project is actually moving.
