Stakeholder Input for RPN 2025-027-030-WS - Occupational Licensing Updates

Comment From: Julia Hunt

11/03/25 @ 9:09 PM

I am writing in support of adding the requirement for 4 hours of Ethics every 3 years for renewal of all public water and wastewater system operator licenses. Operators are faced with making decisions on behalf of water and wastewater systems which ...↓

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Comment From: Elston Johnson

11/03/25 @ 6:33 PM

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Comment From: Virgil Williford

11/03/25 @ 5:53 PM

Ethics training should not be a required to receive or renew a license. Everyone is different and opinions on ethics are as diverse as the people on earth. There is no need for more classes and time to achieve our licensing!

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Comment From: Louis C. Herrin, III

11/03/25 @ 5:53 PM

I am in support of the rule's changes, but I would recommend that the ethics requirements be at least one plus hour each year, and not one four hours class once per license renewal. I have been in the wastewater business for over forty-five years an...↓

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Comment From: Mary Alice McKaughan

11/03/25 @ 5:12 PM

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Comment From: Karen Menard

11/03/25 @ 3:49 PM

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Comment From: Marisa Vergara

11/03/25 @ 1:38 PM

My name is Marisa Vergara. I serve as the Chair for the Texas American Water Works Association. In my role I support over 4500 members which includes licensed operators in water and wastewater treatment systems. I am also a Texas Professional Enginee...↓

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Comment From: Drew Molly

11/03/25 @ 11:25 AM

TCEQ - MC205 - Office of Legal Services
Texas Commission on Environmental Quality
P.O. Box 13087, Austin, Texas 78711-3087

RE: Rule Project Number 2025-027-030-WS

November 3, 2025

Dear Ms. Ricco,

As the Chief Water Officer for the City of Housto...↓

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Comment From: Christianne Castleberry

11/03/25 @ 10:48 AM

Operators are the front line of our industry to ensure clean safe water for our communities. Requiring substantial and meaningful regular ethics training that is combined with their regular license renewals is absolutely essential to continually high...↓

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Comment From: Daniel Nix

11/03/25 @ 10:04 AM

Rule Project Number 2025-027-030-WS
November 3, 2025
Dear Sirs,
As a Licensed Operator in Texas for Water and Wastewater, I strongly support the approval and adoption of the proposed requirement of adding 4 hours of Ethics training to the existing 30...↓

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Comment From: Jesse Huddle

11/03/25 @ 7:58 AM

While ethics is important, it is not something that can be taught to a person. Being ethical is something we are raised to be and mostly common sense. I believe TCEQ should stop trying to money grab and pushing training that is not relevant. It's a w...↓

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Comment From: Adam Armstrong

11/02/25 @ 10:46 AM

Interesting that there appears to be a need to even consider requiring a course in ethics. We don't have courses in our public school systems that instill the precepts of traditional Christian virtues; Prudence, Justice, Fortitude, Temperance, Faith,...↓

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Comment From: Jody Davidson

10/31/25 @ 4:36 PM

I do ethics training every year through my work its required I don't need another 4hrs of training thats gonna cost me more money and time off.

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Comment From: FRANK HASKELL

10/31/25 @ 2:07 PM

Ethics training would be a great elective rather than a requirement for renewal hours. My employer requires it every two years. It takes only about an hour to complete. I am concerned that the petition to require this training has a hypothesis that i...↓

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Comment From: Orlando Villegas

10/31/25 @ 2:05 PM

I support this amendment.

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Comment From: Gary Tompkins

10/31/25 @ 2:05 PM

I think ethics should be mandatory. However, TWQA is not interested in pursuing license enforcement as they feel that would cause more gov scrutiny of our current WTS license system and SOPs. I was told that cause us to do more work or watch what we ...↓

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Comment From: Anonymous Anonymous

10/30/25 @ 11:00 PM

https://www.epa.gov/uic/underground-injection-control-regulations-and-safe-drinking-water-act-provisions

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Comment From: Michael Sjogren

10/30/25 @ 6:06 AM

No need for ethics training. The majority of people will do the right thing. Enforce the existing rules and hold those accountable that don't follow the rules. Simple.

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Comment From: Aaron Heathington

10/29/25 @ 4:17 PM

MAINTANCE TECHNICIANS SHOULD BE REQUIRED TO SOME FORM OF CE HOURS, ALONG WITH THIS ETHICAL TRAINING HOURS. BEING THAT THEY ONLY TAKE A 2 DAY CLASS AND HAVE NO REQUIREMENT TO BE UPDATED ON RULES AND REGS AS WELL AS THE NEW/BETTER WAYS TO PROFORM THEIR...↓

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Comment From: Roger Cowan

10/29/25 @ 10:03 AM

Ethics training as proposed should be dual CEU credits and count towards both water and wastewater. It is an unfair burden to both license holders time and money to require them to take the same exact class twice in license period.

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Comment From: HARLTON TAYLOR

10/28/25 @ 3:38 PM

HOW DO WE GET INVOLVED WITH THIS STAKEHOLDER MEETING I WOULD LIKE TO HAVE A SAID IN THE RULE THAT YALL THINK IS GOOD FOR US AND WOULD LIKE TO HAVE LIST OF THE PEOPLE

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Comment From: Danny Thompson

10/26/25 @ 4:09 PM

Additional training on ethics should only be included in the existing hours to renew your license. As my license in OSSF installer and site evaluator, I see many people trying to evade the existing rules or trying to make up their own special rules....↓

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Comment From: Lee Christian

10/25/25 @ 1:27 PM

As far as an OSSF installer, there needs to time and resources spent on enforcment of illegal installs. The responsibility gets dumped back on understaffed counties and nothing happens. County DAs dont persecute for septics, so if they get caught on ...↓

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Comment From: Jeffrey Poindexter

10/24/25 @ 10:40 PM

I agree with a Jeff Henzler who wrote the following comment:
(I stated in the survey I just took I don't believe the ethics training will do any good not in the long
run anyway. Most supervisors and Lead operators senior operators know the implicatio...↓

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Comment From: Anonymous Anonymous

10/24/25 @ 6:27 PM

The water and wastewater field(operations ) is a very sexist field .im a dual B licenses and somehow my superior do not even have a C license .....there should be some type of regulation for that .

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Comment From: Kevin Walker

10/24/25 @ 3:23 PM

I am a licensed Water Operator in the State of Texas, specializing in Reverse Osmosis systems, water treatment operations. I currently serve as a Department of Defense Contractor, working alongside the U.S. Army and Air Force in the Middle East, main...↓taining and operating critical water infrastructure in demanding, mission-essential environments.

I'm writing to formally oppose the proposed rule under RPN 2025-027-030-WS (Occupational Licensing Updates). This proposal adds unnecessary cost and complexity for working operators while offering no measurable improvement to public safety or system reliability.

Texas already requires ongoing continuing education for every license renewal, which includes ethics, safety, and compliance content. On top of that, most employers including mine already provide mandatory ethics and conduct training as part of annual compliance requirements. Adding a separate ethics training requirement through TCEQ would duplicate existing programs and force operators to pay for redundant content that's already covered by their workplace and CE obligations.

The reality in the field is this: the biggest challenges we face are equipment failures, supply issues, system design problems, and understaffing not ethical misconduct. Introducing another mandatory class won't make the water any cleaner or the systems more reliable. What it will do is generate more revenue for training providers while draining the limited time and money of operators who already work long hours to keep their communities safe and compliant.

As someone who has represented Texas standards abroad while supporting military operations, I take pride in maintaining the highest levels of professionalism and ethics. But I also believe in fairness and practicality. This rule serves no practical purpose other than to charge operators more for what we're already required to do.

I strongly urge TCEQ to reconsider this proposal and focus instead on policies that strengthen operator support such as lowering training costs, expanding access to technical coursework, and allowing operators to complete certification and renewal testing through approved proctored services. Many licensed professionals, including those working out-of-state or overseas, are unable to travel back to Texas for in-person exams, particularly when there's no guarantee of passing on the first attempt. Providing secure, proctored testing options would expand accessibility, retain skilled operators, and help ensure Texas maintains a strong, qualified workforce without creating new financial burdens.

Respectfully,
Kevin Walker

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Comment From: Mark McCasland

10/24/25 @ 2:51 PM

I am also a licensed Professional Engineer in Texas, and, while we are required 1 hour of ethics training per renewal period (annually), the training each year is mostly repetitive. It does include new rules, etc., but still only an hour. I think the...↓

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Comment From: Don McClendon

10/24/25 @ 11:52 AM

I voted against ethics training, not because I don't think it's important, but personally, I have ingrained in me a good ethical background and don't feel the need (personally). But I do believe some licensed personel needs the training if not just f...↓

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Comment From: Angel Negron Monllor

10/23/25 @ 4:20 PM

An ethics class and a third party committee is important in the workplace because improves and boost employees morale and productivity. It would build trust within the stakeholders and the employees work environment knowing that they are being suppor...↓

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Comment From: Pat Jaynes

10/23/25 @ 10:44 AM

I think this is a waste of time and money on the license holder and should not be required. every time we have to go to class and or sit online to do our credits take away from our work day and that cost us money. we write our own checks no one gives...↓

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Comment From: Stacy Wright

10/22/25 @ 4:28 PM

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Comment From: Helen Gates

10/22/25 @ 2:52 PM

Metroplex Training Center is a provider for the BPAT 40-hour course & several CEU courses. I think the 4-hour ethics information could be included in the initial 40-hour course for BPAT & LI & somehow include in an existing CEU course but do not see...↓

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Comment From: Russell Hamilton

10/22/25 @ 1:01 PM

Comments on Specific Operator Training Regarding Ethics

The goal of amending rules for Water and Wastewater Professionals should be carefully considered before imposing new requirements. In broad terms, a lecture or presentation alone seldom teaches...↓ the true foundation of integrity and ethical behavior. Ethics and integrity cannot be forced upon the target audience through additional rules or training mandates.

Few would disagree that well-designed, focused training can have a positive impact. However, believing that simply increasing training hours or requiring specifics in certain areas will improve ethical behavior is questionable. Just like having a speed limit on roadways does not keep everyone from speeding. Many unethical actions happen not because people are "bad," but because they haven't fully considered the ethical implications of their decisions. Ethics training should help individuals think through dilemmas, not just memorize which actions to avoid.

Rather than requiring separate or additional hours of classroom instruction, an alternative could be strengthening the ethics component within the existing Management or Leadership style courses. Integrating ethics discussions into practical, job-related scenarios might achieve the desired results more effectively than a formal rule change or adding content for a lecture series.

It is also important to recognize that training amendments or additions do not automatically result in better behavior. Forcing employees to sit through extended ethics presentations may increase frustration without improving understanding. Ethical decision-making develops through discussion, mentorship, and organizational culture—not repetition of material.

Furthermore, what is considered "fair," "right," or "just" differs among individuals and workplaces. Trying to "reprogram" moral reasoning in two, four, or even eight training sessions is unrealistic. Genuine ethical development takes time, reflection, and ongoing example-setting by leadership. Not implying that ethics should be ignored.

If additional ethics training is to be pursued, there should be a clear and measurable standard for evaluating its effectiveness. How will success be defined? Will improvements be reflected in compliance records, interactions with state personnel, or employee conduct? Without clear metrics, the value of such changes will remain uncertain.

In summary, ethics training can play a supportive role, but it should not be viewed as a cure-all. Ethics is best developed through leadership example, open discussion, and a culture that rewards honesty and responsibility. Rules may set expectations—but it is the daily actions of individuals and supervisors that truly shape ethical behavior within the water and wastewater profession.

If this proposed rule change moves forward, I believe two hours of renewal credit is sufficient.

L. Russell Hamilton
Executive Director
Texas Water Utilities Association

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Comment From: Troy Harbison

10/22/25 @ 12:09 PM

Adding the ethics course to occupational licenses is unethical. It is just another pointless course just like the the resiliency course. If anything it should be a one time course. But if TCEQ is going to waste our time and resources with another poi...↓

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Comment From: John Prince

10/22/25 @ 11:46 AM

I am vehemently opposed to adding to the continuing education requirement for any TCEQ license. To be honest, this appears to be another money grab by CE providers. It's a terrible idea and yet another government burden on small business.

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Comment From: Charles Palcer

10/22/25 @ 9:26 AM

Suggestion: How many low chlorine level letters to DR's and AA's have to send out every month due to homeowners not adding chlorine tablets or liquid to their systems as designed? TCEQ should MANDATE that ALL initial maintenance contracts include p...↓

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Comment From: Stephen Louviere

10/22/25 @ 8:43 AM

I hold my master plumbing license through T.S.B.P.E., my OSSF Installer license is under TCEQ. From that perspective, I believe ethics training is a valuable addition — provided it stays grounded in real field conditions. It should focus on protectin...↓

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Comment From: Cody Alexander

10/22/25 @ 8:29 AM

This is a waste of taxpayers', license holders' and their employers' money and likely by design and intent will only serve to line the pockets of training providers and other special interests. Exactly precise nonsense!

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Comment From: Terry Barber

10/22/25 @ 7:44 AM

I do not support this requirement. The TCEQ is a regulatory agency, not an ethics committee. The staff at TCEQ is very good at what they do, but none of them are qualified to teach ethics, let alone decide what should be taught in an ethics course....↓

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Comment From: Roberto Moralez

10/21/25 @ 9:39 PM

My name is Roberto Moralez & I am a class C wastewater operator for the people El Paso. I have worked in wastewater for three years & have been licensed for two & a half years. I oppose the proposal by WEAT & Texas AWWA to make ethics continuing educ...↓ation mandatory for every operator license renewal.
If they want to offer the training, that's fine. Personally, I'd even be interested in this type of training, but to make it mandatory sends the message that operators cannot be trusted to act ethically unless someone teaches us how. People better than me have guided me in my wastewater career & this petition is an insult to them & the people who have done this job the right way for decades.
In this petition, Texas AWWA & WEAT cite three past cases: the lead contamination crisis in 2014 in Flint, Michigan, the e.coli outbreak in 2000 in Walkerton, Ontario, Canada & the water system failure in Jackson Mississippi. Only the case in Walkerton involved operators falsifying data & it was the plant manager, not the rank & file operators. Even in that case, management failed in their responsibility to ensure of proper training of their operators. Flint & Jackson were failures of government leadership, funding & policy decisions, not from the operators not having ethics training. To mandate ethics training for all license renewals citing these cases lays the blame for these cases at the feet of the average operators, which is inauthentic, & again, insulting. The petition also attempts to compare water & wastewater operators to other licensed professionals, namely, engineers & land surveyors. Us operators are paid far less & hold less authority than those professions, yet they want to hold us to the same standards. This comparison is, again, inauthentic.
Which leads to my next point. Most operators do not make big decisions like the ones that led to the harm of those cited cases. Supervisors & management do. Even if I were to earn my class b license, I would still follow directions from supervisors who usually hold a higher license than mine & certainly more years of experience than I do. It would be reasonable to assume their orders are correct. Supervisors are not going to order obviously unethical orders, which is why the plant manager in Walkerton doctored the results himself. The requiring of ethical training for all license renewals would target more people with the least power. Maybe there's an argument for requiring this training for plant supervisors, but that's not what this petition is suggesting.
To my next point, why would ethics training be required for license renewals & not new licenses? Are Texas AWWA & WEAT assuming new operators are ethical without training? That operators lose ethics over time? Or is this just a checkbox to look good on paper while facing less resistance in order to pass the petition?
The petition also provides no evidence that ethics mandates improve safety. The three branches of the US government require ethics training & a study done by Pew Research in 2024 show that only 16% of Americans say they trust the federal government to do the right thing most of the time. That doesn't sound like ethics training means ethical behavior to me.
I support ethics & safe water, but I do not support blaming the common operator for failures caused by leadership & politics. I do not support mandatory training that assumes we don't know right from wrong.

Thank you for considering the perspective of a common wastewater operator

With respect, Roberto Moralez
Class C Operator
License #WW0075572

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Comment From: Lindsey DeLong

10/21/25 @ 8:27 PM

I would like to suggest that TCEQ consider requiring additional ethical requirement classes for occupational licensing, with a minimum of 8 to 16 extra hours. Furthermore, it is important that companies holding these licenses also be required to unde...↓

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Comment From: David Coon

10/21/25 @ 8:06 PM

I do not think we should have to have more training on ethics. We already learn how important it is to provide people with clean drinking water and how dangerous it is if we do not. I feel like with ever thing that has happened that had a poor impact...↓

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Comment From: juan ramon rodriguez

10/21/25 @ 5:33 PM

This new training is a push back for new operator and current operators. For those doing their job with integrity and professionalism no training is need it, for those who don't care and they are there because the money, any training will change thei...↓

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Comment From: Jeff Henzler

10/21/25 @ 5:07 PM

I stated in the survey I just took I don't believe the ethics training will do any good not in the long run anyway. Most supervisors and Lead operators senior operators know the implications of falsifying documentation or doctoring samples. When we h...↓

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Comment From: Randy Williams

10/21/25 @ 3:45 PM

As someone who started in the field as a laborer and now serves as a Director, I've seen firsthand how hard Operators (Line Crews) work and how little they're often paid in return. The responsibilities keep growing — more certifications, more regulat...↓

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Comment From: Donald Shockley

10/21/25 @ 3:44 PM

As an "A" water operator in my 28th year serving the state of Texas, the recent trend of adding additional training during each short 3-year license cycle is concerning. These "specialty" concerns should be just added as parts of existing training. B...↓

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Comment From: Benny Lewis

10/21/25 @ 3:28 PM

Additional training is going to be a burden to some operators and employers. The training required is not yet available, widespread, or affordable. Rural areas still don't have reliable internet to take online classes and would include days off wor...↓

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Comment From: Samuel Samaniego

10/21/25 @ 3:14 PM

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Comment From: Monica Wallace

10/21/25 @ 3:10 PM

Too many installers are forcing homeowners to install aerobic systems when a standard will work. Too many maintenance providers are not reporting dates and times and finding as required. Too many failing aerobic spray heads are being allowed to exi...↓

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Comment From: EDGAR FRANCO

10/21/25 @ 3:06 PM

I truly suggest it should be all Liscenses not just Water and Wastewater Treatment Liscenses.

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Comment From: Zachary Jackson

10/20/25 @ 11:46 AM

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Comment From: Eric Kong

9/25/25 @ 12:42 PM

I am strongly against adding this requirement for Operator licensure. The proposed outline is not well-developed to identify the costs, impacts to existing licensure, or available training opportunities. For example, requiring additional training hou...↓

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Comment From: Luke Hill

9/25/25 @ 11:58 AM

In reference to Rule Project Number 2025-027-030-WS. I would like to go on record saying that I do not believe requiring another 4-hour ethics course for the renewal of a water license will be beneficial. While it may be requested with good intention...↓

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