Stakeholder Input on Upcoming Rulemaking Related to 30 TAC Chapter 39 and Chapter 55

Comment From: Susybelle Gosslee

10/11/24 @ 12:00 AM

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Comment From: Brian Zabcik

10/08/24 @ 11:56 PM

Statement by Save Barton Creek Association on Upcoming Rulemaking Related to 30 TAC Chapter 39 and Chapter 55

Save Barton Creek Association would like to thank TCEQ for the opportunity to submit comments on possible rule changes to 30 TAC Chapters 3...↓

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Comment From: Deyadira Arellano

10/08/24 @ 11:55 PM

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Comment From: Becky Smith

10/08/24 @ 6:30 PM

Please see uploaded file with comments.

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Comment From: Inyang Uwak

10/08/24 @ 5:21 PM

To whom it may concern:

Thank you for the opportunity to provide comments on Rule Project Number 2024-003-039-LS.

To ensure meaningful community engagement, TCEQ needs to reduce barriers to participation and create a culture of transparency, accou...↓ntability, and trust. They should also demand the same from facilities seeking new permits/renewals.

I ask that TCEQ prioritize community participation and input before considering the application. Making a preliminary decision before considering community input is NOT community engagement.
All improvements to the permit process should apply to all kinds of permits. Providing 36 hours more after the end of a public meeting or hearing for comment submission would be a powerful change to ensure meaningful input and action by the affected public.

I ask that the TCEQ Adopt a Cumulative Impact Assessment in the review of all Draft Permits to ensure meaningful community input. Participation in environmental decisions by members of the public who are directly affected by those decisions is a moral imperative, and efforts are necessary to ensure that community members are aware of and can easily participate in environmental decision-making processes conducted by public agencies. While I appreciate TCEQ providing this additional rule-making opportunity, I must also call attention to the fact that these recommendations—and the critical concerns underlying them—have been raised with TCEQ persistently and repeatedly for at least a decade and, still, the people directly affected by TCEQ permitting decisions, who are predominately people of color and lower-income, continue to bear the disproportionate adverse health and other effects of inadequate environmental protection, despite their pleas to the contrary while actively participating in permit hearings, comment periods, and other participation opportunities. The need for a "more meaningful opportunity for public input" was also noted in the Sunset Review of the agency. One concrete and impactful shift to achieve the "meaningful public input" goal is for TCEQ to use a Cumulative Impact Assessment to review Draft Permits. TCEQ's current and continued assertion that it cannot consider any permit application in relation to another does not pass the reasonable person standard.

TCEQ must be fundamentally committed to considering community members' needs and concerns in its decision-making. This does not end with the opportunity to provide information and comment, but for that information and comment to have true influence over TCEQ's decisions. Permit applicants should also be required to inform nearby sensitive-use areas within the minimum permitted distances, such as elementary schools, high schools, daycares, and hospitals, when a permit has been submitted to the TCEQ.

To that end, the use of modern and best-practice air quality modeling for permit applications is also recommended. Texas remains the only state in the country not using AERMOD, as the American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee (AERMIC) recommended.

Finally, clarify explicitly the minimum distance requirements between permitted facilities, particularly permits for new permanent construction, and use cumulative air emissions calculations when modeling impact within such minimum distances.

Thank you.

Sincerely,
Inyang Uwak, DrPH, MPH, MD.
Research & Policy Director
Air Alliance Houston

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Comment From: Eric Allmon

10/08/24 @ 4:06 PM

Please see the attached comments submitted on behalf of Bayou City Waterkeeper, Coastal Alliance to Protect our Environment, Environmental Stewardship, Friends of Hondo Canyon, Greater Edwards Aquifer Alliance, Hillcrest Residents Association, Ingles...↓

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Comment From: Amy Dinn

10/08/24 @ 10:45 AM

Attached please find comments submitted by Lone Star Legal Aid on behalf of Better Brazoria.

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Comment From: Mark Hesterlee

10/03/24 @ 6:48 PM

When companies are putting profit over people, that profit needs to be hit hard for them to listen. Please continue to focus enforcement on repeat violators (like W.A. Parish) and increase penalties. Therefore, I am in favor of more vigilance, more r...↓

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Comment From: Walter Wagnon

10/03/24 @ 4:34 PM

I'm in full support of Senate Bill 1397 aka TCEQ sunset bill. It is of paramount importance that air quality that can affect people's health is priority over a company's profit. Violators, especially repeat violators, need increased penalties to get...↓

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Comment From: Sarah Hesterlee

10/03/24 @ 9:12 AM

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Comment From: David Tomlinson

10/03/24 @ 7:28 AM

I think the removal of a required High School Diploma to be a major setback to our profession. There is no reason to "dumb it down " for someone who lacks the drive to finish school. I understand that there are certain hardship cases but still most p...↓

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Comment From: Donna Thomas

10/01/24 @ 11:45 PM

project number 2024-003-039-LS.

Why this matters:

- Senate Bill 1397 proposes important updates to public participation, including emailing permit notices directly to residents near facilities and allowing 36 hours for public comments after TCEQ m...↓

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Comment From: Ana Parras

10/01/24 @ 11:29 PM

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Comment From: Elita Castleberry

8/06/24 @ 2:35 PM

Harris County Pollution Control Services respectfully submits the comment letter as a pdf.

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Comment From: david smith

8/02/24 @ 8:07 PM

This is an additional comment. I support the 36 hour extension of public comments after a public meeting. Due to the nature of possible crowd intimidation or subject matter possibly raised by officials during the meeting, comments should be availab...↓

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Comment From: david smith

8/02/24 @ 7:47 PM

Changes should be made to public notice. 1.TCEQ should not allow public notice to proceed unless posting at physical site is confirmed and maintained through the comment period. 2. It should be confirmed that applicant is following and abiding by T...↓

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Comment From: Lisa Brenskelle

8/02/24 @ 4:41 PM

Enhanced Public Engagement and Opportunities for Participation

(a) Increase Public Engagement: To ensure broad participation, especially from marginalized communities, hold pre-application informational sessions, workshops, and community meetings at...↓

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Comment From: Adrian Shelley

8/02/24 @ 3:51 PM

Please see attached.

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Comment From: Elizabeth Hidalgo

8/02/24 @ 1:03 PM

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Comment From: Rachel Hanes

8/02/24 @ 12:50 PM

Revised file.

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Comment From: Lori Kier

8/02/24 @ 12:34 PM

Please see attached comments.

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Comment From: Rachel Hanes

8/02/24 @ 12:07 PM

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Comment From: Gina Biekman

8/02/24 @ 9:21 AM

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Comment From: Aimee Wilson

8/02/24 @ 9:17 AM

The United States Environmental Protection Agency (EPA) has prepared comments for consideration regarding the 30 Texas Administrative Code (TAC) Chapter 39, Public Notice and Chapter 55, Requests for Reconsideration and Contested Case Hearings: Publi...↓

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Comment From: H.C. Clark

8/01/24 @ 5:54 PM

Comment: Landfill permit applications should be posted online and remain there after the permit is issued.
The present situation: Landfill permits are posted (now by TCEQ, previously by the would-be operator) through the permitting process and any ap...↓peals, then taken down. The permit applications should remain online and easily "findable" by the public.
A permit application is more than a few boxes on a form. It describes what's behind the fence and is the only comprehensive source of information a neighbor might find--a neighbor concerned first about the concept of a new landfill, then later when the landfill is operational and a problem that might lead to enforcement. The application is a stand alone document that serves as a contract that the landfill makes with the public--its geologic framework, how it will operate, and the standards it will follow (e.g. gwsap, lfg, etc.).
The argument for taking a landfill permit application down is that once final, it's no longer an application and doesn't fit 330.57 i.
That's word play and not what we intended when first recommending the plan. 330.57 i says that the permit application must be posted. It does not say the permit application may be taken down. For years, when the operators were required to do the posting, we were told that internet storage space was too expensive; that response no longer applies, because the applications exist and are now permanently stored by TCEQ--it's a matter of public access to the information.
I don't think I am alone. Following a scathing evaluation of the TCEQ, the Sunset Commission made a number of recommendations; one was specific to this point:
Require TCEQ to review and update its website to improve accessibility and functionality, including by posting all permit applications and associated materials on TCEQ's website once the agency determines the application to be administratively complete and by making its database of water districts easily accessible to the public and regional water planning groups.
This afternoon, I tried both your records site and you home page--testing for Atascocita Landfill, Waco Landfill, UEC Goliad Mine (a mine, not a landfill). No luck.
image.png
Your answer may be that the landfill applications are there, and you understand the Sunset Commission's criticisms and you are working on it, and that would be a good answer. In the meantime, a reasonable stopgap would be set of sample searches on your present Oracle site, demonstrating that a landfill application, and a lot of other information valuable to the public, is easily "findable".

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Comment From: Citizens Against Ellis County MUDs, Inc. (CAECM) Anonymous

8/01/24 @ 3:55 PM

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Comment From: Molly Smith

7/31/24 @ 6:36 PM

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Comment From: abigail Youngblood

7/31/24 @ 3:31 PM

1. Improved display of public notices via:
-Printed notices posted in public areas

-Printed notice published in a local paper with the largest area circulation

-Signs posted on the applicant's premises of adequate size to read while driving past
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Comment From: Jane Voisard

7/26/24 @ 3:32 PM

Proposed rule project 2024-003-039-LS
I appreciate any opportunity to interact with TCEQ representatives in person and I did attend the Arlington session. I encourage your agency to continue this type of public input — including on more controversial...↓

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Comment From: Jane Voisard

7/26/24 @ 3:05 PM

I've attached a PDF of my comments regarding the proposed rule project 2024-003-039-LS. The PDF contains a photo of signage to illustrate my points about the need to change graphic standards and add needed information to these important roadside noti...↓

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Comment From: Ann Jensen

7/22/24 @ 2:39 PM

I have long felt out of the loop on TCEQ permit reviews. Please expand your communications plan by offering broader and more timely public notice for permits and actions affecting water quality. Utilize the postal service to mail print materials in a...↓

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Comment From: Rachel Sanborn

7/22/24 @ 8:17 AM

I would like to see the public better informed of permits and actions affecting water quality especially over the Edwards Aquifer. I also think you should make these items and notices easily accessible to the public through a variety of means- search...↓

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Comment From: Ana Parras

7/18/24 @ 6:34 PM

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Comment From: Jaclyn Morris

7/18/24 @ 3:02 PM

I support
Enhanced Public Notice Requirements: Expanding the scope of public notice for permits and actions affecting water quality

Increased Accessibility:
Ensuring that public notices are more easily accessible and understandable to the community...↓

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Comment From: Mary Branch

7/18/24 @ 12:35 PM

See attached PDF

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Comment From: Jacob Hendrickson

7/18/24 @ 11:20 AM

30 TAC Chapter 39 - Public Notice
Enhanced Public Notice Requirements: Expanding the scope of public notice for permits and actions affecting water quality.
Increased Accessibility:
Ensuring that public notices are more easily accessible and understa...↓

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Comment From: Eli Hilbert

7/11/24 @ 4:07 PM

Dear TCEQ Commissioners,
I am writing to comment on the proposed rulemaking to amend 30 TAC Chapter 39 and Chapter 55 on Project Number 2024-003-039-LS.
Enhanced Public Engagement and Opportunities for Participation
Increase Public Engagement: Hold p...↓

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