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...↓
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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.↓
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introducing produced water onto farmland poses many of the same risks and health concerns that were associated with biosolids, particularly PFAS contamination. However, produced water presents additional concerns as well.
First, produced water origin...↓ates deep underground in geological formations that were created when much of Texas was covered by ancient seas. 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 origin...↓ates deep underground in geological formations that were created when much of Texas was covered by ancient seas. 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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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,
Water, water, everywhere and not a healthy drop to drink. 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 r...↓ulemaking 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
Regarding Rule Project Number 2026-006-309-OW
Please allow time to research alternatives and the impact of this decision. At Cedar Creek Lake we live with TRWD compliance which governs waste water. Citizens request a pause on all these actions unti...↓l the impact can be evaluated.↓
Please allow time to research alternatives and the impact of this decision. At Cedar Creek Lake we live with TRWD compliance which governs waste water. Citizens request a pause on all these actions unti...↓l the impact can be evaluated.↓
No attachments
As industrial use of chemicals is rapidly changing and increasing, it is imperative that we pause and consider the regulations that need to be implemented to protect the agricultural production in our state and the residents living near these facilit...↓ies.
The arsenic laced affluent from Teslas lithium operation has highlighted a disparity of oversight currently (Texas Tribune, USA, and other have reported on this and the response/lack of response from TCEQ has been deeply concerning).
Let's not just be a place known for industry, let's be a place known for industry done well.
I highly encourage you to check Good Jobs "Violation Tracker" for big tech - they've made it clear that they will not be regulating themselves. It is the responsibility of the state and its citizens to implement and uphold guard rails to protect the next generation of Texans.
https://violationtracker.goodjobsfirst.org/↓
The arsenic laced affluent from Teslas lithium operation has highlighted a disparity of oversight currently (Texas Tribune, USA, and other have reported on this and the response/lack of response from TCEQ has been deeply concerning).
Let's not just be a place known for industry, let's be a place known for industry done well.
I highly encourage you to check Good Jobs "Violation Tracker" for big tech - they've made it clear that they will not be regulating themselves. It is the responsibility of the state and its citizens to implement and uphold guard rails to protect the next generation of Texans.
https://violationtracker.goodjobsfirst.org/↓
No attachments
This is absolutely heinous and will have devastating health, environmental, and economic impacts. For once, stop bowing down to whatever oil and gas lobby has you on their payroll and do the right thing. This is in no way, shape, or form a future tha...↓t any Texan wants.↓
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,
As a Permian Basin mineral owner, I concur with comments by Commission Shift and submit my comments on Rule Project Number 2026-006-309-OW submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking o...↓n 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 an inheritor of oil and gas mineral rights from my grandfather's business as a landman. Even as someone who benefits financially from oil and gas production, I am deeply concerned about the environmental and human health impac...↓ts. 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
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
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,
As a retired environmental scientist and former TCEQ employee with 34 years of state service I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land applicatio...↓n 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.↓
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I am writing to urge the TCEQ to reject the proposed rule allowing companies to spread treated
produced water on land. Drinking water and farmland should not be negatively impacted ever, let alone with the proposed rule. Making our state a dumping gr...↓ound is bad. Vote NO on this, and side with safeguarding agriculture, the environment and in turn, public health.↓
produced water on land. Drinking water and farmland should not be negatively impacted ever, let alone with the proposed rule. Making our state a dumping gr...↓ound is bad. Vote NO on this, and side with safeguarding agriculture, the environment and in turn, public health.↓
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I have concerns regarding SB 1145, allowing produced water to be applied to the ground via sprinkler and other irrigation systems. Simply stated this is a a bad idea, especially if there is no oversite. How will this water be purified to rid it from ...↓the chemicals that are used in the refining process or is the plan to allow water that is essentially contaminated with solvents, chemicals, salts and metals to have easier access into our watersheds without accountability? Where will this water be spread? Near neighborhoods, schools, or communities at large? This is essentially contaminated waste water that is being put into the water cycle, which is a closed system with limited usable water for drinking for people, plants and other living beings. I humbly ask that you consider all aspects of this bill SB 1145 and in doing so keep in mind future generations, don't leave them a bigger mess to contend with in the future. Thank you.↓
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Based on the potential for real long-term agricultural and environmental damage, I request that you allow the following:
1. More time to comment, with hearings held in affected regions.
2. Real setbacks — from public water sources, and from schools...↓, churches, residences, and daycares, all scaled to documented spill distances.
3. Real testing — for the contaminants known to be in produced water (heavy metals, radium, PFAS, industrial solvents), by independent certified labs.
4. Real transparency — public disclosure of chemical contents, application volumes, testing data, and the science behind the rule.
Thank you for keeping Texans safe.↓
1. More time to comment, with hearings held in affected regions.
2. Real setbacks — from public water sources, and from schools...↓, churches, residences, and daycares, all scaled to documented spill distances.
3. Real testing — for the contaminants known to be in produced water (heavy metals, radium, PFAS, industrial solvents), by independent certified labs.
4. Real transparency — public disclosure of chemical contents, application volumes, testing data, and the science behind the rule.
Thank you for keeping Texans safe.↓
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Toxic wastewater should not be allowed to flow into our rivers, creeks, lakes, or to be used on farmland. Whatever happened to "don't mess with Texas?" We should be protecting our natural resources, not allowing oil and gas companies to destroy them!
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Please see attachment for a request to extend public comment period. Thank you for your consideration.
Attachments:
Commission Shift formally requests a 30-day extension of the comment period.
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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