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Occupational licensing: TCEQ adds resiliency requirement, provisional Class D pathway and clarifies deficiency process
Summary
TCEQ occupational licensing staff described March rule changes that add a two-hour resiliency overview to new and upgrading water licenses, create two-year provisional Class D licenses for those without a high school diploma or GED, and require applicants to notify licensing when clearing application deficiencies.
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Teresa (TCEQ Occupational Licensing) briefed the Drinking Water Advisory Work Group on rule updates that took effect March 23 and affect public water system operators’ licensing and renewal paths.
The rules add a resiliency requirement tied to basic training. Teresa said the basic water (Class D) pathway now requires 22 hours for initial licensing: a 20-hour basic water-work course plus a 2-hour resiliency overview. The 2-hour resiliency continuing-education requirement also applies to renewals; continuing-education totals did not increase, but 2 hours must be resiliency-focused within renewal cycles.
Provisional Class D licenses exist for applicants without a high school diploma or GED, Teresa said; those provisional registrations last two years and cannot be renewed but can be upgraded to a full license after the applicant meets education requirements. The provisional option was already implemented operationally and is now codified in rule.
Teresa also described a change to application-deficiency procedures: applicants must both clear a deficiency (for example, missing training hours) and notify Occupational Licensing by the date listed in the deficiency letter so staff know the deficiency has been addressed. The rule change followed missed deadlines caused by updates performed electronically that Licensing staff did not automatically detect.
Other updates include clearer delivery-method definitions for approved training (in-person, live online, self-paced), a resiliency column on the individual search page (it marks continuing-education resiliency only), and a reduction in LPST renewal hours from 32 to 20. Teresa said the office mailed notices about electronic delivery of exam analysis and approval letters beginning January 2025 and had collected more than 1,500 updated email addresses.
Teresa asked systems and training providers to watch the TCEQ website for the full rule language and for updated lists of approved resiliency providers.

