Authors: Melanie Klamar, Alan Ideris, & Shelley Ragsdale | December 19, 2024

In 2023, the Texas State Legislature approved Senate Bill 1397 and House Bill 1505, which require that “A person who holds a temporary permit or permit with an indefinite term shall report to the commission annually whether the activity subject to the permit is ongoing” and that the person “shall first report to the Texas Commission on Environmental Quality the status of the permitted activity not later than December 31, 2024”. The Texas Water Code has been amended to include this requirement in Sec. 5.587.

Which Permits are Subject to the New Requirement?

Despite its name, the Texas Water Code applies to air, water and waste programs that fall within Texas Commission on Environmental Quality (TCEQ) jurisdiction. The TCEQ Air Permits Division has announced that registered Permits by Rule (PBRs), Standard Exemptions and certain Air Quality Standard Permits are subject to the statutory reporting requirement.

How Do I Comply?

Subject air permits must be registered through the State of Texas Environmental Electronic Reporting System (STEERS) by December 31, 2024 and annually thereafter.

TRC Can Help

If you are uncertain if your permits are subject to the new reporting requirements, need assistance navigating STEERS, or have other environmental permitting needs, TRC’s Regulatory Compliance Specialists in Texas and across the country who can help.

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Melanie Klamar

Melanie Klamar is a Senior Project Manager and National Service Leader for Air Quality Consulting. She has more than 22 years of consulting experience and has been with TRC since her career began. Her technical expertise is in air permitting and environmental compliance. Contact Melanie at mklamar@trccompanies.com.

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Alan Ideris

Alan Ideris brings over 19 years of environmental consulting expertise, specializing in compliance programs for industries such as power plants, petrochemicals, oil and gas, and steel manufacturing. His skills include emissions inventory, calculation development, permitting (PSD/NNSR/NSR), regulatory interpretation, and air compliance audits. He is highly experienced in air quality modeling and has contributed to several PSD permit applications. Additionally, Alan has conducted emissions measurements using CFR test methods, including international stack testing campaigns, and possesses strong knowledge of meteorological instruments and observations. Contact Alan at AIderis@trccompanies.com.

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Shelley Ragsdale

Shelley Ragsdale has extensive multidisciplinary experience in regulatory compliance, permitting, auditing, and emergency response across industrial, consulting, and governmental sectors. Her expertise spans air, water, waste, spill planning, and chemical reporting, with leadership roles focused on compliance systems development, regulatory applicability, and multimedia environmental auditing. Her career highlights include subject matter expertise in multi-media permitting and compliance across industries such as petrochemical manufacturing, aerospace, oil and gas, and waste treatment. Contact Shelley at sragsdale@trccompanies.com.