TCEQ reports more than 600 MS4 applications; paper annual reporting to continue until EPA restores Net MS4 module

The Texas Commission on Environmental Quality told participants at its fall Water Quality Advisory Work Group meeting that it has received more than 600 applications for the 2024 Phase II MS4 general permit (TXR040000) and has approved 145 renewal notices of intent (NOIs).

“ We received over 600 applications,” Rebecca Villalva, team leader for the TCEQ stormwater team, said as she described the agency’s review process. She said 489 applications remain “on hold” in the review queue, with 126 currently under active review and 36 NOIs that staff cannot act on because of functionality issues in the Texas Net MS4 system that TCEQ is addressing with EPA.

Why it matters: The 2024 permit was renewed on Aug. 15, 2024, and required electronic submission through the Texas Net MS4 application system; the application deadline was Feb. 11, 2025. TCEQ said that in the Net MS4 system a notice of deficiency is presented as a denial with comments that applicants may correct and resubmit, and that the agency honors the original submission date for federal reporting purposes.

TCEQ also announced that, because EPA has paused development of the Net MS4 annual‑report module, permittees should continue to submit annual reports on paper using the 2019 or the updated 2024 annual report templates as appropriate until TCEQ announces otherwise. “The electronic reporting module in Net MS4 is not ready,” Villalva said, and the division will post updates on its website and at future work‑group meetings.

TCEQ advised permittees approved late in the year that reporting should be prorated for any partial reporting period and encouraged permittees with unique fiscal‑year situations to contact the SWGP mailbox for case‑specific guidance.

Next steps: TCEQ will continue reviewing pending applications, work with EPA to resolve the 36 blocked NOIs, and notify permittees when the Net MS4 annual‑reporting module is available.