Rule 37 Pack & `rrc_rule37` Skill

This page documents the RRC oil & gas vertical — one of the five packs installed on AEGIS. The mechanisms (packs, skills, routers, HITL rules) are domain-neutral.

The rule_37 pack and the rrc_rule37 skill cover spacing-exception filing under Texas Administrative Code 16 TAC 3.37. A user reaches this capability in a general-mode conversation through the spacing router (pull_routers → select_skill) — there is no dedicated “Rule 37 agent” to pick anymore. The pack helps operators prepare Form W-1 applications when a proposed well location falls within the standard spacing distances defined by the Railroad Commission of Texas (RRC).

How it is reached

Mechanism	Value
Pack	`rule_37` (`packs/rule_37/manifest.yaml`)
Skill key	`rrc_rule37`
Router	`spacing` → `rrc_rule37`
Compliance domain	`rule_37`
Entity types	`Well`

The effective LLM model is tenant-configured via Platform Settings (box default anthropic/claude-sonnet-5) — it is not pinned per skill.

Regulatory Context

Rule 37 (16 TAC 3.37) defines the minimum spacing distances for oil and gas wells in Texas. The statewide-floor defaults live in the pack’s assessment recipe and are shared with the skill’s code (thresholds resolve from rule_versions for SWR_37 over these floors):

Spacing Requirement	Statewide floor
Lease-line minimum (`lease_line_min_ft`)	467 feet
Between-well minimum (`between_well_min_ft`)	1,200 feet

Any well proposed closer than these distances to existing wells or lease lines requires a spacing exception. The operator must demonstrate “good cause,” notify affected offset operators, and file a Form W-1 or W-1A with the RRC.

Field-specific rules can override statewide spacing. The agent queries RRC field rules for the target field before applying statewide defaults, and flags recent amendments.

Skills in the pack

The rule_37 pack declares eleven skills. Most are code-backed (orchestration.skills.rule37.*); rule37_readiness_check is a declarative readiness_check descriptor.

Skill key	Item	Purpose
`rule37_exception_type`	Exception Type Determination	Analyze well position vs. field rules / statewide defaults; determine lease-line, between-well, or both; compute exact distances
`rule37_field_rules`	Field Rule Lookup	Query RRC field rules; identify applicable spacing rules; flag amendments
`rule37_offset_identification`	Offset Well Identification	Query the knowledge graph + RRC public data for wells within the notification radius; compute distances; identify operators via P-5
`rule37_service_list`	Affected Party Service List	Compile offset operators, lessees, and unleased mineral owners; flag stale addresses
`rule37_waiver_tracking`	Waiver Collection Status	Track waivers, flag 6-month expirations, generate waiver-request letters
`rule37_form_w1`	Form W-1 Population	Pre-fill W-1 fields from entity data (operator P-5, lease, location, distances, exception type)
`rule37_surveyor_package`	Certified Plat	Generate a surveyor data package (coordinates, boundaries, offsets, field-rule spacing)
`rule37_good_cause`	Good-Cause Statement	Draft the waste/confiscation-prevention narrative with reserves, drainage, and precedent
`rule37_technical_exhibits`	Supporting Technical Exhibits	Compile decline curves, spacing analysis, and geological data
`rule37_fee_calculation`	Fee Calculation	Compute the filing fee from TVD per the SWR 3.78 schedule
`rule37_readiness_check`	Filing Readiness Check	Validate that all required fields, service list, plat, fee, and mandatory items are complete

Checklist & assessment

The pack’s checklist template defines the eleven items above (indices 0–10) and the min_required_items for submission (0, 1, 2, 3, 5, 7, 10). The pack’s assessment recipe (five-verb DSL) runs two threshold_compare checks — distance-to-lease-line vs. lease_line_min_ft and distance-to-nearest-well vs. between_well_min_ft — and marks an entity action_needed when either is under the resolved threshold. This is the same authoritative source used by the skills, which fixed the 467/1200 drift.

HITL Checkpoints

HITL travels with the rrc_rule37 skill as seeded require_hitl rules, not with any agent identity:

Rule key	Checkpoint	Trigger
`skill:rrc_rule37:pre_filing`	`pre_filing`	Filing assembly, before RRC submission
`skill:rrc_rule37:good_cause_review`	`good_cause_review`	The good-cause narrative

The approval_node is fail-closed — it pauses (awaiting_hitl) rather than proceed unreviewed when a mandatory checkpoint cannot be recorded.

Skill-scoped tools

Once rrc_rule37 is loaded, its code-block tools become available (they are not core tools): spacing_calculation, offset_well_analysis, rule37_filing_assembly, and good_cause_narrative. Filing assembly is the HITL-gated mutation.

Form	Full Name	Purpose
W-1	Application for Permit to Drill, Recomplete, or Re-Enter	Primary drilling permit application filed with the RRC
W-1A	Amended W-1	Filed when modifications to an existing permit are needed

Example Interaction

In a general conversation, a user provides basic well information:

“I need to file a Rule 37 exception for Mitchell Ranch 1H. The proposed location is 350 feet from the south lease line on the Mitchell Ranch lease in the Spraberry (Trend Area) field.”

The agent pulls the spacing router, loads rrc_rule37, and then:

Recognizes 350 ft is below the 1,200 ft between-well floor (and any stricter Spraberry field rule)
Calls spacing_calculation to quantify the variance
Calls offset_well_analysis to identify affected parties on adjacent leases
Drafts a good-cause narrative citing the distances, field rules, and technical justification
Assembles the Form W-1 package
Pauses at the pre_filing and good_cause_review HITL checkpoints

Rule 37 Pack & rrc_rule37 Skill