Land Application of Produced Water - RPN 2026-006-309-OW
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I care about the land and water in Texas.
Please do what is right, and follow Commission Shift's recommendations!
I approve the following message. I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW r...↓egarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards are in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I have great concerns about the proposed use of treated produced water that could pollute soils, waterways, and the environment. I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the propos...↓ed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards are in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
My comment is that this produced water should be thoroughly tested regularly and frequently. Since Texas is the state with the most produced water to deal with it should have a plan in place that protects our water sources and farmlands. I have not...↓ been impressed with TCEQ's oversite of environmental issues in the past and feel that they are way too industry friendly. If I understand correctly this water contains heavy metals, salts, fracking chemicals and other containments that we would not want contaminating our farmland.↓
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Dear Gwen Ricco,
I am a family member of a person who owns mineral rights in Texas. While you might assume that mineral rights owners would not support limiting the extraction industry in favor of the environment, that is not true in my case. I drea...↓m of a future with clear air, clean water, healthy ecosystems, and connected communities and I am writing to support that dream.I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards are in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Our company, Circle Verde Water, successfully operated a produced water desalination system in multiple locations throughout West Texas and New Mexico. During operation of this plant near Big Spring, TX the New Mexico Produced Water Research Consorti...↓um gathered samples that were extensively evaluated and the results published. The freshwater from our plant exceeded EPA Drinking Water standards and was found to be cleaner than the municipal water available in most West Texas towns.
We relocated this plant to another oilfield site. At this location our plant processed flowback water, tank bottoms, drilling mud after solids removal and other aqueous oilfield wastes. During this time, a representative from an Israeli firm that wishes to partner with us gathered and analyzed water samples. From their independent analysis, they found the freshwater effluent from our plant was suitable for irrigation without issue.
Videos of this plant in operation, including sample gathering and investigation may be found at the links below:
https://youtu.be/4Jlp3tlvrwA
https://youtu.be/fEY1oG12kl0
https://youtu.be/ca7csI0e-Wc
My team and I would be delighted to address any questions you may have or schedule a virtual and/or in-person meeting
Thank you for your consideration,
Joseph V Alexander, PhD PE
↓
We relocated this plant to another oilfield site. At this location our plant processed flowback water, tank bottoms, drilling mud after solids removal and other aqueous oilfield wastes. During this time, a representative from an Israeli firm that wishes to partner with us gathered and analyzed water samples. From their independent analysis, they found the freshwater effluent from our plant was suitable for irrigation without issue.
Videos of this plant in operation, including sample gathering and investigation may be found at the links below:
https://youtu.be/4Jlp3tlvrwA
https://youtu.be/fEY1oG12kl0
https://youtu.be/ca7csI0e-Wc
My team and I would be delighted to address any questions you may have or schedule a virtual and/or in-person meeting
Thank you for your consideration,
Joseph V Alexander, PhD PE
↓
In order to create effective rules for oil fracking water reclamation, you need to know all the chemicals that are used in the fracking water. Otherwise you are just poisoning us and the environment.
If you are unable to get this information, then f...↓racking water remains a highly hazardous water and needs to be regarded legally as hazardous to human life and the environment.
Please extend the public comment period by 30 calendar days.↓
If you are unable to get this information, then f...↓racking water remains a highly hazardous water and needs to be regarded legally as hazardous to human life and the environment.
Please extend the public comment period by 30 calendar days.↓
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Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
It is unacceptable to let fracked water be used on farms without definitive information about the dangers this water poses to food grown on this land or the groundwater with which it will combine. Please protect Texans from harmful chemicals and make...↓ sure we can maintain a healthy food supply!↓
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I see at least a partial solution to two problems here. The first problem is linked to water scarcity, in particular the potential use of millions of gallons by proposed and existing data centers. The second problem is the overabundance of produced w...↓ater and how to clean it for use. It seems that this water could be cleaned enough to be used by data centers and other industries for their cooling needs. This way, clean water would be reserved for consumption and irrigation of food crops which is so desperately needed.↓
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I urge you to stop considering the use of toxic fracking water on crops. I instead suggest it be used in data centers since are a huge drain on our water resources. Cleaning would also be needed for this so as not to add to air pollution through ev...↓aporation, but this still seems much safer.↓
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I am writing to oppose proposals that would allow treated oilfield produced water to be applied to farmland and ranch land, or discharged into rivers, streams, and other waterways.
Produced water from oil and gas operations is fundamentally differen...↓t from municipal or agricultural wastewater. It contains high concentrations of salts (chlorides, sodium, and total dissolved solids) that can render soil infertile, degrade crop yields, and take years or decades to remediate once soils are damaged. It also routinely contains heavy metals such as arsenic, barium, and cadmium, naturally occurring radioactive materials (NORM/TENORM) brought up from deep geologic formations, and organic compounds including benzene, toluene, and other BTEX chemicals associated with cancer and other serious health effects.
A particular concern is the presence of PFAS and other chemicals used in hydraulic fracturing fluids, many of which are protected as trade secrets and are never fully disclosed to regulators or the public. Current treatment technologies, including reverse osmosis and other advanced processes, are not proven to reliably remove all of these contaminants, and PFAS in particular are persistent, do not break down in the environment, and accumulate in soil, crops, livestock, and ultimately in the people who eat them.
Applying this water to farmland risks contaminating the soil that produces our food, the groundwater that supplies drinking water wells, and the forage that livestock consume, with effects that may not become apparent for years. Discharging it into waterways threatens aquatic ecosystems, downstream water users, and irrigation supplies, with no guarantee that monitoring will catch problems before harm occurs.
Before any such reuse is permitted, there should be comprehensive, independent, peer-reviewed studies on the long-term effects of treated produced water on soil health, crop and livestock safety, and human health, full public disclosure of the chemicals involved, and treatment standards proven effective for the full range of contaminants present, not just the limited set currently tested for.
Until those conditions are met, treated oilfield wastewater should not be approved for use on agricultural land or discharge into waterways. The risks to our food supply, water resources, and public health are too significant, and too poorly understood, to proceed.↓
Produced water from oil and gas operations is fundamentally differen...↓t from municipal or agricultural wastewater. It contains high concentrations of salts (chlorides, sodium, and total dissolved solids) that can render soil infertile, degrade crop yields, and take years or decades to remediate once soils are damaged. It also routinely contains heavy metals such as arsenic, barium, and cadmium, naturally occurring radioactive materials (NORM/TENORM) brought up from deep geologic formations, and organic compounds including benzene, toluene, and other BTEX chemicals associated with cancer and other serious health effects.
A particular concern is the presence of PFAS and other chemicals used in hydraulic fracturing fluids, many of which are protected as trade secrets and are never fully disclosed to regulators or the public. Current treatment technologies, including reverse osmosis and other advanced processes, are not proven to reliably remove all of these contaminants, and PFAS in particular are persistent, do not break down in the environment, and accumulate in soil, crops, livestock, and ultimately in the people who eat them.
Applying this water to farmland risks contaminating the soil that produces our food, the groundwater that supplies drinking water wells, and the forage that livestock consume, with effects that may not become apparent for years. Discharging it into waterways threatens aquatic ecosystems, downstream water users, and irrigation supplies, with no guarantee that monitoring will catch problems before harm occurs.
Before any such reuse is permitted, there should be comprehensive, independent, peer-reviewed studies on the long-term effects of treated produced water on soil health, crop and livestock safety, and human health, full public disclosure of the chemicals involved, and treatment standards proven effective for the full range of contaminants present, not just the limited set currently tested for.
Until those conditions are met, treated oilfield wastewater should not be approved for use on agricultural land or discharge into waterways. The risks to our food supply, water resources, and public health are too significant, and too poorly understood, to proceed.↓
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Introducing produced water onto farmland poses many of the same risks and health concerns that are associated with biosolids, particularly PFAS contamination. However, produced water presents additional concerns as well.
First, produced water origina...↓tes deep underground in geological formations.These shale formations can contain naturally occurring radioactive materials at levels that exceed what many people would consider safe. Exposure to elevated levels of radiation can pose serious health risks. If this water is applied to farmland used for growing crops or raising livestock, there is concern that radioactive contaminants could enter the food chain and eventually be consumed by people. The potential health impacts should not be ignored.
Second, studies have shown that produced water can contain significant levels of PFAS chemicals. PFAS are man-made substances that do not occur naturally in the environment and are often referred to as "forever chemicals" because they persist for long periods of time. Scientific research has linked PFAS exposure to reproductive problems, certain cancers, and a variety of other health issues. These concerns make the use of produced water on agricultural land particularly troubling.
Regardless of which concern is examined—radioactive contamination or PFAS exposure—the potential risks are significant. Many people view the root of this issue as placing financial interests above public health and safety.↓
First, produced water origina...↓tes deep underground in geological formations.These shale formations can contain naturally occurring radioactive materials at levels that exceed what many people would consider safe. Exposure to elevated levels of radiation can pose serious health risks. If this water is applied to farmland used for growing crops or raising livestock, there is concern that radioactive contaminants could enter the food chain and eventually be consumed by people. The potential health impacts should not be ignored.
Second, studies have shown that produced water can contain significant levels of PFAS chemicals. PFAS are man-made substances that do not occur naturally in the environment and are often referred to as "forever chemicals" because they persist for long periods of time. Scientific research has linked PFAS exposure to reproductive problems, certain cancers, and a variety of other health issues. These concerns make the use of produced water on agricultural land particularly troubling.
Regardless of which concern is examined—radioactive contamination or PFAS exposure—the potential risks are significant. Many people view the root of this issue as placing financial interests above public health and safety.↓
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United States. Very strict rules are needed to make sure toxic chemicals are removed and that the water is continually monitored for violations. Otherwise I will assume that the food grown in Texas is toxic and will only buy food produced outside of ...↓this state.↓
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I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards are in place to prot...↓ect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can't grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can't grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
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Any request to use treated water should include a provision that the applicant's officers, board members, and those in charge of the cleaning operation must drink a glass of it or eat whatever is grown or raised with it on a periodic basis.
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Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
The Greater Edwards Aquifer Alliance is a nonprofit organization dedicated to the protection and
preservation of the Edwards and Trinity aquifers, their springs, watersheds, and the Texas Hill Country
that sustains them. Our alliance has 59 member ...↓groups across 21 counties in the Texas Hill Country region.
We work in this field to ensure the protection of the health, safety, and welfare of all those who rely on
these sources of water. As such, we appreciate the opportunity to submit the following comments and
questions on this rulemaking.
SB 1145 (89r) directed the TCEQ to adopt TLAP standards specifically for produced water. The legislation
made no mention of general industrial wastewater streams. The Chapter 309 section of the proposed
rule, however, refers repeatedly to establishing standards for land application of "industrial waste water,
including produced water." Why has the rulemaking been extended beyond the scope of the legislation
it is intended to implement?
The proposed new waste streams are extremely different than the domestic sewage waste streams
currently included in the rules. All limits and specifications are related to nutrient concentrations and
nutrient handing and recycling in the soil and land. Produced water and industrial waste are likely to have
little nutrient content relative to the metals and other contaminant constituents present. Current
established design guidance, application limits, etc. are entirely insufficient for the new sources of waste.
Why do the limits and specifications proposed remain relevant only to domestic sewage waste streams
and do not take into account the different constituents present in the industrial and produced streams?
Produced and industrial water waste streams will have specific pretreatment requirements, yet there is
no mention of these requirements in the context of this rulemaking. TLAP application of produced water
should not be considered without specific pretreatment requirements, verification of the incoming waste
stream contents, and significant revisions of the acceptance criteria for water quality of the applied waste
onto the land surface. Why are these specific requirements and revisions not included in this proposed
rule?
Produced water is not equivalent to existing domestic waste streams and it is a significant error to handle
them as if they were. There is no effective remediation of produced water and industrial waste
components by applying them to the soil – the existing criteria for safe disposal are inadequate and highly
unlikely to be protective of surface or groundwater supplies. Why does the proposed rulemaking rely on
soil application for the remediation of produced and industrial waste components?
Furthermore, TCEQ is not currently able to adequately monitor existing TLAP sites much less new and
non-domestic sewage TLAP sites. There is virtually no oversight and most sites are self-regulated by
operators. The rulemaking indicates no cost burden to the transition to TCEQ from the RRC or for the
rulemaking. How can TCEQ accommodate the extra burden of this rulemaking without additional funds
or personnel?
As noted in the language of SB 1145, there is supposed to be a separate establishment of limits associated
with the produced water reclamation and discharge. Instead, there is some reference to a single pilot
study and no mention of establishing specific limits for the pretreatment of these waste streams in the
rulemaking. Why was this step omitted?
At a high level, we agree that if the state is going to authorize the use of produced water for irrigation of
lands and crops, the TCEQ should regulate its use and should adopt water treatment standards. What we
do not agree with, however, is the weak treatment standards actually laid out in this proposed
rulemaking. Produced water should not be treated the same as municipal wastewater. We need much
stricter standards for treatment and more robust testing protocols to ensure our food and water is kept
safe from the constituents found in produced water. There are no long-term, real-world studies that prove
treated produced water can be used to irrigate crops or land safely.
The draft rule proposes 250- to 500-foot setbacks from public and private water supply wells for
application of produced water. Texas counties, in contrast, require domestic waste water treatment
plants to be spaced anywhere from ¼ acre to 5 or 10 acres away from water supply wells. Setbacks for
application of produced water should be consistent with county requirements for separating the use of
produced water from wastewater discharges. At a minimum, TCEQ should require setbacks of one acre
from water supply wells for land application of produced water.
At a more granular level, we have significant concerns about the potential for land application of produced
water over the Edwards Aquifer Recharge and Contributing zones. The Edwards Aquifer is an incredibly
sensitive and prolific karst limestone aquifer, highly susceptible to pollution and contamination.
Regardless of the standards established, and we do hope stricter standards are established, we request
that TCEQ prohibit the land application of produced water over the Edwards Aquifer Recharge and
Contributing zones.
We also request the TCEQ extend the public comment period. TCEQ has not provided the appropriate
public notice or comment period to ensure that concerns are adequately addressed.↓
preservation of the Edwards and Trinity aquifers, their springs, watersheds, and the Texas Hill Country
that sustains them. Our alliance has 59 member ...↓groups across 21 counties in the Texas Hill Country region.
We work in this field to ensure the protection of the health, safety, and welfare of all those who rely on
these sources of water. As such, we appreciate the opportunity to submit the following comments and
questions on this rulemaking.
SB 1145 (89r) directed the TCEQ to adopt TLAP standards specifically for produced water. The legislation
made no mention of general industrial wastewater streams. The Chapter 309 section of the proposed
rule, however, refers repeatedly to establishing standards for land application of "industrial waste water,
including produced water." Why has the rulemaking been extended beyond the scope of the legislation
it is intended to implement?
The proposed new waste streams are extremely different than the domestic sewage waste streams
currently included in the rules. All limits and specifications are related to nutrient concentrations and
nutrient handing and recycling in the soil and land. Produced water and industrial waste are likely to have
little nutrient content relative to the metals and other contaminant constituents present. Current
established design guidance, application limits, etc. are entirely insufficient for the new sources of waste.
Why do the limits and specifications proposed remain relevant only to domestic sewage waste streams
and do not take into account the different constituents present in the industrial and produced streams?
Produced and industrial water waste streams will have specific pretreatment requirements, yet there is
no mention of these requirements in the context of this rulemaking. TLAP application of produced water
should not be considered without specific pretreatment requirements, verification of the incoming waste
stream contents, and significant revisions of the acceptance criteria for water quality of the applied waste
onto the land surface. Why are these specific requirements and revisions not included in this proposed
rule?
Produced water is not equivalent to existing domestic waste streams and it is a significant error to handle
them as if they were. There is no effective remediation of produced water and industrial waste
components by applying them to the soil – the existing criteria for safe disposal are inadequate and highly
unlikely to be protective of surface or groundwater supplies. Why does the proposed rulemaking rely on
soil application for the remediation of produced and industrial waste components?
Furthermore, TCEQ is not currently able to adequately monitor existing TLAP sites much less new and
non-domestic sewage TLAP sites. There is virtually no oversight and most sites are self-regulated by
operators. The rulemaking indicates no cost burden to the transition to TCEQ from the RRC or for the
rulemaking. How can TCEQ accommodate the extra burden of this rulemaking without additional funds
or personnel?
As noted in the language of SB 1145, there is supposed to be a separate establishment of limits associated
with the produced water reclamation and discharge. Instead, there is some reference to a single pilot
study and no mention of establishing specific limits for the pretreatment of these waste streams in the
rulemaking. Why was this step omitted?
At a high level, we agree that if the state is going to authorize the use of produced water for irrigation of
lands and crops, the TCEQ should regulate its use and should adopt water treatment standards. What we
do not agree with, however, is the weak treatment standards actually laid out in this proposed
rulemaking. Produced water should not be treated the same as municipal wastewater. We need much
stricter standards for treatment and more robust testing protocols to ensure our food and water is kept
safe from the constituents found in produced water. There are no long-term, real-world studies that prove
treated produced water can be used to irrigate crops or land safely.
The draft rule proposes 250- to 500-foot setbacks from public and private water supply wells for
application of produced water. Texas counties, in contrast, require domestic waste water treatment
plants to be spaced anywhere from ¼ acre to 5 or 10 acres away from water supply wells. Setbacks for
application of produced water should be consistent with county requirements for separating the use of
produced water from wastewater discharges. At a minimum, TCEQ should require setbacks of one acre
from water supply wells for land application of produced water.
At a more granular level, we have significant concerns about the potential for land application of produced
water over the Edwards Aquifer Recharge and Contributing zones. The Edwards Aquifer is an incredibly
sensitive and prolific karst limestone aquifer, highly susceptible to pollution and contamination.
Regardless of the standards established, and we do hope stricter standards are established, we request
that TCEQ prohibit the land application of produced water over the Edwards Aquifer Recharge and
Contributing zones.
We also request the TCEQ extend the public comment period. TCEQ has not provided the appropriate
public notice or comment period to ensure that concerns are adequately addressed.↓
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As a south Texas farmer, I'm concerned that these regulations may not be sufficient to protect public health and agricultural safety. The potential daily application of millions of barrels of produced water requires stringent standards to prevent the...↓ accumulation of harmful substances in soil and water. The 30-day comment window is insufficient for the public to evaluate these draft rules and echo the request a 30-day extension of the comment period to allow for more informed feedback. Please also consider in-person hearings in communities most likely to be impacted (Permian Basin, Eagle Ford, and East Texas).↓
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Please,for God's sake and ours, DO NOT ALLOW fracking water to be used for land application ANYWHERE!! Also, DO NOT allow Data Centers to be built on land that has had Biosolids applied to and more likely than not, is loaded with toxic chemicals like...↓ PFA'S↓
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I don't need oilfield wastewater contaminating my land, crops, and water wells! I worked in that industry. I know what they put in that frack and drilling water, and I don't want it poisoning my land that I worked hard to keep clean! And, I want t...↓he unfettered right to sue oil and drilling companies for any damage they do to my land or water wells.
↓
↓
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Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
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