Key Takeaways
- TCEQ's main enforcement priority during this administration will be "compliance first" – meaning the agency is taking a more business-friendly approach, focusing on helping companies get into compliance before utilizing enforcement tools.
- TCEQ will be hiring over 175 new full-time equivalent employees in air, water, and waste sectors to help address TCEQ's current workload and backlog.
- TCEQ Chairwoman Paup anticipates expanded EPA deregulation beyond the 31+ rollbacks to date, with uncertain impacts on Texas permitting and enforcement.
Brooke Paup was appointed as Chairwoman of the Texas Commission on Environmental Quality (TCEQ) on January 7, 2025, and unanimously confirmed by the Texas Senate in May 2025. In June 2025, Chairwoman Paup spoke to the Houston Bar Association's Environmental Law Section about her first few months in office and where the agency is heading. Here's what she had to say.
- TCEQ is the second-largest environmental agency in the world. Texas is also growing by approximately 1,358 Texans per day. This influx of growth causes more strain on resources and necessitates the need for more permits and oversight. However, TCEQ is understaffed, causing backlogs in core activities, such as permit issuance and research. To that end, TCEQ requested and recently received permission to hire 175.5 new full-time equivalent employees. Per Chairwoman Paup, these new employees will be split amongst air, water, and waste, including outreach and engagement. This hiring boost will hopefully help address TCEQ's current workload and backlog. The agency will also be holding two or three meetings/hearings per month to quicken permits.
- TCEQ regulates air, water and waste. But when the presidential administration swings, so do the regulations. The second Trump administration has announced a rollback of 31-plus environmental regulations but has not yet issued guidance on what that means for each state. Chairwoman Paup anticipates that the Environmental Protection Agency (EPA) will also be rolling back other environmental regulations as part of the administration's deregulation effort, but state agencies still need to perform their own analysis and figure out how these deregulation efforts will impact agencies at the state level.
- With respect to the relationship between TCEQ and EPA Region 6, Chairwoman Paup relayed that they have had great interagency communication. They are currently working on integrating priorities and the path forward.
- When asked whether there are any specific enforcement priorities for TCEQ during this new administration, Chairwoman Paup said, "compliance first." The goal of the agency is to help get companies into compliance, before moving to enforcement. This is a more business-friendly approach for the agency.
- Senate Bill 7, primarily concerning water infrastructure and funding under the jurisdiction of the Texas Water Development Board, was signed into law by Gov. Greg Abbott in June 2025. In November 2025, SB7 will be voted on by Texas voters in the constitutional amendment election. If approved in November, up to $20 billion will go toward water infrastructure projects over the next two decades. Per Chairwoman Paup, this is a generational investment in water for the state of Texas, but it remains to be seen how funds would be distributed.
- Ex parte rules about when and how communications can be made to TCEQ by the Governor, Lieutenant Governor, and other members of the legislature are under review. Senate Bill 3074 would expand the agency's ability to have such communications regarding matters pending before the agency. SB3074 still needs to be voted on by the House of Representatives and signed into law by the Governor, but it has been fast-tracked.
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