Ms. Kris Hogan
MC 205, Office of Legal Services
Texas Commission of Environmental Quality
P.O. Box 13087
Austin, TX 78711-3087
July 23, 2019
COMMENTS TO THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Re: 2016-042-309-OW: Amendments of Chapters 222 and 309 Relating to Beneficial Reuse Credits
LEAGUE OF WOMEN VOTERS OF TEXAS
The League of Women Voters of Texas appreciates the opportunity to comment on the proposed rule changes
regarding beneficial reuse of wastewater. Our positions on water and land use issues are derived through a
lengthy and thoughtful process involving the participation of 31 local Leagues representing more than 7,000
members and supporters throughout the state of Texas.
Our members support policies that emphasize conservation and reuse of water; that are based on research
concerning wise and efficient use of the state’s land and water resources; that protect the land and fragile
ecosystems; and that maintain groundwater quality by preventing harmful contamination of aquifers.
LWVTX SUPPORTS the efforts of TCEQ to respond to increasing demands on water supplies and decreasing
availability of tracts of land for domestic wastewater disposal under the current rules. We believe the proposed
rule changes will help prevent degradation of water quality from wastewater discharge and will promote
beneficial reuse of water.
Specifically, LWVTX SUPPORTS these proposed rules changes in particular:
1. The commission proposes §222.83(e) and §309.24(d) to prohibit reducing the disposal site area by more than 50% of
the area required based on the permitted flow.
We agree that this percentage of land must be available in case there is more reclaimed water available than can be
reused. The rule is a safeguard against unauthorized discharge.
2. The commission proposes §222.127(c) and §309.24(e) to prohibit the reduction of the required storage.
We agree that this rule is another important safeguard against unauthorized discharge.
3. The commission proposes new §309.25(b)(5) to require a permittee that is granted a beneficial reuse credit to have a
contractual agreement to pump and haul unused treated effluent and requires the applicant to dispose of excess
wastewater under the contractual agreement…(under certain conditions).
We believe this new rule would ensure certainty that the permittee is prepared to deal with excess reclaimed water,
and again would safeguard against unauthorized discharge.
4. The commission proposes new §309.25(c)(5) to require the permittee to submit their monthly effluent monitoring
reports to the executive director.
1212 Guadalupe St., Suite 107 Austin, TX 78701 512.472.1100 [email protected] www.lwvtexas.org