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Public commenter raises legal challenges to ex‑parte rules and applicability to MS4 permits
5775022 · September 4, 2025
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Summary
A member of the public argued that Water Code section 13287 and the disclosure model are invalid and urged the board to address ex‑parte communication rules for MS4 and stormwater permits.
During public forum on Sept. 3, Ray Tahir (self‑identified as chief counsel for TEX Environmental) asked the board to address what he described as legal inconsistencies in the board’s ex‑parte and disclosure provisions. Tahir said "13287 was not amended" and asserted that bracketed definitions added to a 2019 version are invalid because…
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