2025 WQSM Seminar Insights

The Texas Commission on Environmental Quality (TCEQ) recently hosted the 2025 Water Quality and Stormwater (WQSM) Seminar, which brought together consultants, agency staff, and other stakeholders to discuss current challenges and program updates within the Water Quality Division (WQD). The seminar provided a detailed look at ongoing rulemakings, workload trends, permitting priorities, and new initiatives related to wastewater and stormwater.

Organization Changes and Staffing

On September 1^st, 2025, structural changes were implemented in the WQD to support growing program areas. WQD’s Permitting Section was reorganized into two sections: Industrial Wastewater and Domestic Wastewater. Additionally, an Oil and Gas Permitting Team was created under the Industrial Wastewater Section. The WQD also recruited new staff members to address this new workload distribution.

Despite these efforts, the WQD continues to face staffing pressures after a 25% turnover rate in the past year; this was after salary increases and other retention measures were implemented.

Workload and Application Trends

WQD’s workload continues to remain a challenge due to the large number of Treated Wastewater Discharge Permit (TPDES) applications in recent years:

• Fiscal Year (FY) 2022: 50 applications received
• FY2023: 80 applications received
• FY2024: 70 applications received

The mix of applications being sent to the WQD is something to note. One part of the mix is coastal desalination projects, which were touched on in the seminar due to their technical complexity and extensive modeling; for instance, sometimes weeks of water modeling are required, particularly for diffusers.

Additionally, domestic wastewater discharge applications have tended to accumulate, creating a review surge that can affect the permitting process timeline.

Growing Public Interest

There has been an increase in public engagement on water quality permits. Some of these trends include an increase in the quantity and complexity of comments during public notice periods and higher attendance at public meetings. The number of contested case hearings has more than doubled, growing from 14 in 2024 to 30 in 2025. This can impact the permitting process for clients by increasing the timeline and adding legal preparation costs.

Modeling and Review Challenges

Water quality modeling causes delays in permitting and was identified as a major challenge in the permit review process because there has been an increase in the complexity and quantity of applications.

In order to aid in this challenge, WQD is evaluating the third-party modeling option that could allow third parties to perform the required modeling for permitting, while TCEQ would review those modeling efforts. This would increase review efficiency and result in a more timely processing of TPDES applications.

Other Important Program Requirements

WQD reiterated a few policy and program requirements during the seminar including:

• Regionalization: A requirement where new domestic discharges must evaluate whether existing treatment plants in a defined radius can accept their wastewater discharge. This helps prevent a cluster of discharges.
• House Bill (HB 3333): Discharges are prohibited in certain river segments and drainage areas. The enrolled version of this bill can be found here.
• Treated Produced Wastewater: Applications for treated produced wastewater discharges are authorized through the Railroad Commissions of Texas (RRC) and coordinated with TCEQ under 30 Texas Administrative Code (TAC) §7.117 (Memorandum of Understanding between RRC and TCEQ).

Legislative and Rulemaking Updates

TCEQ also provided updates on several bills that have been passed or are being considered in recent legislative sessions including:

• Authority granted to TCEQ for land application of produced water
  • TCEQ was granted the authority to issue permits for land application of produced water from mining and oil and gas extraction operations through Senate Bill (SB) 1145.
  • This applies to permits filed on or after September 1, 2025, and the enrolled version of the bill can be found here.
• Fast-tracking of liquefied natural gas export terminals
  • TCEQ implemented an expedited review process for applications to construct or modify liquefied natural gas export terminals and authorizes an additional expedited fee for applicants through SB 2037.
  • This applies to permits filed on or after September 1, 2025, and the enrolled version of the bill can be found here.
• Restrictions placed on general permit coverage for discharging waste
  • Facilities are restricted from applying for or maintaining coverage under general permits for discharging waste into or adjacent to Texas waters if the commission denies or suspends discharge under a general permit under SB 1302. Existing coverage could be suspended until compliance performance improves.
  • This applies to permits filed on or after September 1, 2025, and the enrolled version of the bill can be found here.
• General permits prohibited for high-level radioactive waste storage
  • TCEQ is prohibited from issuing general permit coverage for facilities engaged in storage of high-level radioactive waste through HB 4112. The agency will update applicable general permits to reflect this.
  • This applies to permits filed on or after September 1, 2025, and the enrolled version of the bill can be found here.
• Updates to perfluoroalkyl and polyfluoroalkyl substances (PFAS) and commercial fertilizer definitions
  • New definitions for PFAS and amendments to the definitions of commercial fertilizer to include biosolids were proposed in SB 886.
  • This bill did not pass, but the introduced version can be found here.
• Updates to design criteria for domestic wastewater treatment systems and subsurface area drip disposal systems (SADDS)
  • Updates to Chapter 217 were proposed including requirements for treatment processes, definitions, and standards for new technologies.
  • Updates to Chapter 222 were proposed including design criteria for SADDS and ensuring upstream treatment units meet Chapter 217 standards.
  • 2026 is the proposal target.
• Updates to implementation procedures (IPs)
  • Updates to TCEQ’s Procedures to Implement the Texas Surface Water Quality Standards (RG-194) were proposed including definitions, human health criteria permit limits, temporary standards, and bacteria criteria.
  • 2026 is the proposal target.

Oil and Gas Wastewater Permitting

Updates to the framework on managing discharges of treated, produced water were provided at this seminar. Produced water volumes are enormous because with every barrel of oil produced, there are approximately seven barrels of water generated. Because Texas produces about four million barrels of oil every day, that means there are over one billion gallons of water produced daily. Given Texas’s projected six-million-acre-foot water shortage by 2026, treated produced water could help with water management solutions.

Permitting for produced water discharges differs between the water-rich east and the arid west of the 98^th meridian in the United States. Currently, however, there is limited produced water being discharged to surface water as most of it is being reinjected using wells. To expand downstream water availability, TCEQ is developing a permitting pathway to encourage and streamline produced water discharges to surface waters within watersheds. Proposed updates to the permitting pathway around produced water discharges include:

• Whole Effluent Toxicity (WET): Being established “in reverse,” meaning limits are being established before extensive discharge data collection.
• Tiered Discharge Volumes: Initial discharge volumes will start at around 300,000 gallons per day (GPD), with a potential increase up to 1 million GPD after six months of demonstrated compliance. This allows for an iterative evaluation of environmental impacts on surface water.
• Treatment Requirements: Treatment trains will be required to remove/treat pollutants such as metals, naturally occurring radioactive metals (NORM), and volatile and semi-volatile organic compounds (VOC/SVOC).
• No Dilution or Mixing: Discharges where effluent flow may exceed the receiving water flow will be required to operate without dilution or mixing.
• Non-Compliance Reporting: Persistent or consecutive non-compliance events with trigger corrective action plan (CAP) requirements.

Upcoming Milestones

• Draft Texas Multi-Sector General Permit (TXR050000): Published November 14^th, beginning a 30-day public comment period. A public meeting will be held on December 15^th in Austin, Texas.
• Design Criteria for Domestic Wastewater Treatment Facilities: Proposed updates will be released in Spring 2025.

Final Thoughts

For industrial clients navigating these changes to Texas’ water quality programs, ALL4 offers support to ensure compliance with both state and federal requirements. If you have any questions or would like to discuss how ALL4 can help you with these efforts, please reach out to Cody Fridley at 269.716.6537 or cfridley@all4inc.com.