Protests remain elevated, Delaware leads new filings, and permit timelines continue to diverge by basin.
Permian saltwater disposal well (SWD) permitting activity remained active through Q4 2025 and into early 2026. Application volumes were steady through year-end before softening in January. Approval cadence varied month to month, and permit timelines extended compared to last year — particularly in the Midland Basin.
The data reflects a basin where disposal demand remains intact, but protest exposure, approval conditioning, and geographic shifts are shaping outcomes.
Protest Activity: Elevated and Concentrated
Protests continue to be a defining feature of the current permitting environment.
Across this filing window, approximately 40% of submitted applications show at least one protest recorded. Protest frequency peaked in December, when more than half of filings were protested.
By basin:
- The Delaware Basin saw protests on roughly 45% of submitted applications.
- The Midland Basin saw protests on roughly one-third of filings.
Protest activity was concentrated among several operators in high-density disposal corridors, including Loving and Reeves Counties in the Delaware Basin and Midland and Upton Counties in the Midland Basin.
While protests do not automatically prevent approvals, they introduce procedural complexity and can affect timing. When drafting a long-term takeaway agreement that includes new disposal well construction with committed injection start dates, protest risk is a material planning and scheduling consideration.
Disposal Demand Holds Steady, But Permit Timelines and Conditions Tighten
Permian disposal permitting activity remained steady through Q4, with filings consistent in October through December before moderating in January. Approval volumes followed a similar pattern, strongest in October and December and lighter in early 2026. Underlying disposal demand remains intact, though timing variability is evident.
A material portion of approvals were issued with reduced permitted volumes or surface pressure limits, reinforcing that requested capacity does not necessarily translate to permitted capacity.
Year-over-year time to permit increased in both major basins. The Midland Basin saw the more pronounced increase in approval timelines, while the Delaware Basin experienced a more modest rise but continues to carry longer absolute processing times.
Basin-Level Summary
Delaware Basin
The Delaware Basin accounted for roughly 60% of submitted applications and just under 50% of approvals during this review window. Protest exposure was elevated, with approximately 45% of filings showing at least one protest. Time to permit increased modestly year over year relative to the Midland Basin. The Delaware currently represents the most active disposal permitting environment in the Permian.
Midland Basin
The Midland Basin represented approximately one-third of new submissions and just under 40% of approvals. Protest frequency was lower than in the Delaware but remained significant at roughly one-third of filings. The Midland experienced the sharpest year-over-year increase in permit timelines. A higher share of approvals in this basin were issued with reduced daily liquid volume limits.
Central Basin Platform (CBP)
The CBP accounted for approximately 5% of submitted applications but a higher share of approvals at roughly 14%, reflecting steady but limited activity. Protest activity was minimal relative to the Delaware and Midland basins. Overall permitting trends in the CBP remain comparatively stable year over year.
What This Means for Operators and Water Midstream
Three factors will be important to watch in the coming months:
- Protests are more frequent in core disposal corridors.
Protest exposure should be incorporated into siting and scheduling assumptions. - Permitting timelines are diverging by basin.
Midland lead times have increased materially year over year. - Approval conditioning is common.
A meaningful share of permits are issued below requested volume or pressure limits.
Disposal capacity remains available across the Permian, but it is increasingly shaped by pressure conditions, protest dynamics, and basin-specific regulatory timelines.
For upstream and water midstream teams, disposal planning remains an active engineering and commercial variable.
The full Underground Injection Control (UIC) Report — including operator-level detail and historical comparisons — is available from B3 Insight.
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