Land Application of Produced Water - RPN 2026-006-309-OW
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I am writing to formally submit my comments on Rule Project Number 2026-006-309-OW regarding the proposed rulemaking on the land application of treated produced water. This rulemaking is critical to ensuring that robust standards ar...↓e in place to protect public health and the environment. Because Texas law limits liability for operators that meet the rules the TCEQ sets, it is vital these rules be sufficient to protect our health and create a paper trail that proves companies meet this high bar.
Our livelihood counts on clean water. Our communities count on it to thrive–to attract investment and to keep our children healthy as they grow. Without clean water, we can’t grow our crops or feed the livestock we take to market. It is vital that our water and soils remain safe — and that the public can trust they are safe.
The draft rules, as currently written, do not provide a sufficient regulatory framework to protect Texas communities and businesses. And 30 days is insufficient time to prepare comprehensive comments to point out all deficiencies–let alone review any technical basis that exists. As such, I request that the TCEQ extend the public comment period by 30 days to allow a more comprehensive analysis.
This rule will affect communities across this state, especially those with significant oil and gas production. A single public hearing in Austin and virtually is insufficient to hear from those communities. Please schedule public hearings in impacted communities across the Permian Basin, the Eagle Ford Shale, and the East Texas Basin.
To protect Texas communities, our agricultural industries, and environment, the final TCEQ rule must include:
— Permitting Transparency: A formal permitting process that includes ample public notice and a robust protest system for affected communities.
— Basic Design Safeguards: Include common-sense requirements standard in municipal treatment. This includes stricter setback distances, mandatory public testing disclosure, and a rigorous paper trail to ensure tracking and accountability throughout the supply chain.
— Uniform Minimum Standards: Clear, mandatory health-protective limits based on type of land application and geography instead of flexible, case-by-case regulatory discretion.
— Strict Contaminant Limits: Explicit caps on known toxins, including heavy metals, PFAS, and radionuclides, ensuring water is fully treated to safe standards.
— Continuous 24/7 Testing: Mandatory, around-the-clock monitoring to ensure compliance at all times, not just rare scheduled checks.
— Independent Audits: Mandatory third-party testing to verify industry self-reporting.
— Open Data Access: Full public access to testing data—modeled after municipal water quality testing requirements—with no "proprietary information" loopholes used to hide chemical data.
— Bioaccumulation Tracking: Required baseline soil and crop testing to track and intercept toxic buildup in our food chain.
The TCEQ must ensure that these rules are based on rigorous, independent science rather than limited industry test data. As such, this rulemaking is premature because the science does not exist; therefore, the barriers to obtaining a permit should be high, and the required testing for any permits granted should ensure they help fill all scientific gaps.
Please update the docket to reflect my request for an extended comment period and stronger rule enforcement. Please protect our communities.↓
No attachments
Dear Gwen Ricco,
I 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
We have serious concerns regarding the proposed regulations and their potential failure to protect public health and agricultural safety. Given that millions of gallons of produced water could be applied to land daily, leading to the accumulation of ...↓harmful constituents in the ecosystem if the rules are inadequate, it is essential that these regulations be thorough and stringent.
Because this rule will apply to technologies unproven at scale for removing unknown chemicals with unknown environmental exposure risks, a 30-day comment period is inadequate for the public to fully evaluate the rules. We formally request a 30-day extension to the public comment period to develop comprehensive, formal feedback. Additionally, more in-person public meetings should be held in communities in the Permian Basin and Eagle Ford that are most likely to be impacted by land application of treated water.↓
Because this rule will apply to technologies unproven at scale for removing unknown chemicals with unknown environmental exposure risks, a 30-day comment period is inadequate for the public to fully evaluate the rules. We formally request a 30-day extension to the public comment period to develop comprehensive, formal feedback. Additionally, more in-person public meetings should be held in communities in the Permian Basin and Eagle Ford that are most likely to be impacted by land application of treated water.↓
No attachments
The current state of this proposal does not have adequate language regarding how TCEQ will ensure spreading treated oil-field wastewater stays within the internationally recognized limits for safe treated industrial waste meant for reuse. While I do ...↓not think moving oversight of this from Texas Rail Road Commission to the TCEQ is inherently flawed, I do think more work, evidence, and technical information needs to be provided before expanding the use of unproven experimental uses of treated oilfield waste water on crops.↓
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Regarding Rule Project No. 2026-006-309-OW:
I am writing to urge the TCEQ to reject the proposed rule allowing companies to spread treated produced water on land. Oilfield wastewater contains dangerous heavy metals, radium, and salts that pose sever...↓e, long-term health risks to Texans—especially developing children. Spreading this water on land threatens our agricultural soil, risks contaminating downstream drinking water supplies, and endangers public health. Texas should not become a dumping ground for oil and gas wastewater. Please protect our communities and vote no on this rule.↓
I am writing to urge the TCEQ to reject the proposed rule allowing companies to spread treated produced water on land. Oilfield wastewater contains dangerous heavy metals, radium, and salts that pose sever...↓e, long-term health risks to Texans—especially developing children. Spreading this water on land threatens our agricultural soil, risks contaminating downstream drinking water supplies, and endangers public health. Texas should not become a dumping ground for oil and gas wastewater. Please protect our communities and vote no on this rule.↓
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I am very concerned about proposals to apply waste water on the surface. Given the known
toxicity, as well as lack of knowledge and disclosure about these waters, it is essential that full fluid and site testing be done before any permits are issued,...↓ and any permits must be developed with full transparency and full public participation, and permit recipients must have good compliance histories and bonding, with strict cleanup requirements imposed.↓
toxicity, as well as lack of knowledge and disclosure about these waters, it is essential that full fluid and site testing be done before any permits are issued,...↓ and any permits must be developed with full transparency and full public participation, and permit recipients must have good compliance histories and bonding, with strict cleanup requirements imposed.↓
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I am writing to express my strong opposition to authorizing the land application of treated oil and gas produced water. This change poses unacceptable, irreversible risks to Texas communities, agricultural industries, and foundational water resources...↓. The primary mission of the TCEQ is to protect our state's public health and natural resources. This rulemaking prioritizes the oil and gas industry's waste disposal convenience over the safety of Texas citizens, soil, and ecosystems. I urge the Commission to withdraw this proposal and maintain strict prohibitions against the land application of produced water.↓
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Produced water contains known and unknown pollutants, including unknowable variation in the concentration of known and unknown pollutants. The uncontrolable variation in pollutants in produced water makes it unsuitable for land application.
In short...↓, land application of produced water is indistinguishable from an uncontrolled spill of produced water.
Prohibit land application of produced water.↓
In short...↓, land application of produced water is indistinguishable from an uncontrolled spill of produced water.
Prohibit land application of produced water.↓
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Sounds like the state rePUBICLANS way of murdering land owners by allowing oil and gas to be used on properties in order to poison the soil and any vegetation and if the day is over 100 then that soil could become combustible very quickly destroying ...↓property, animals, and people!!!!!!!!!!!!!!!!!!!!!!↓
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It is imperative that these waters be tested for contaminants, then a filtration process performed BEFORE it is simply sprayed on the Earth!!!! The very notion that this contaminated water be allowed to further contaminate the soil, groundwater, wild...↓life is UNCONSCIONABLE!!!!↓
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I am deeply concerned about proposals to apply produced water on the surface. Given the known toxicity, as well as lack of knowledge and disclosure about these waters, it is essential that full fluid and site testing be done before any permits are is...↓sued, and any permits must be developed with full transparency and full public participation, and permit recipients must have good compliance histories and bonding, with strict cleanup requirements imposed.↓
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Produced water contains chemicals, salts, and metals. These new rules will directly affect Texas soil, groundwater, and public health. It is absolutely essential for the health and well-being of all Texans the TCEQ implement strict clean-up standards...↓, environmental testing, and transparency before any permits are approved. It is past time for the TCEQ to start living up to its name and ACTUALLY protect environmental quality and Texas citizens.↓
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I understand that the Texas Commission on Environmental Quality (TCEQ) is deciding new rules for SB 1145. I believe that allowing "produced water" (wastewater from oil and gas operations) to be applied to the ground via sprinkler or other irrigation...↓ systems is dangerous to the environment. This "land application" allows water contaminated with chemicals, salts, and metals to be spread on the ground, affecting Texas soil, groundwater, and public health. As a Texas resident, I ask you to insist on strict clean-up standards, environmental testing, and transparency before any permits are approved.↓
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