TCEQ says 600+ MS4 applications submitted; electronic annual-reporting module paused as EPA work remains limited
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Summary
The Texas Commission on Environmental Quality reported receipt of more than 600 Phase 2 MS4 applications and said 145 have been approved while 489 remain on hold; a planned electronic annual‑reporting module in the Texas Net MS4 system is paused pending EPA resources, so annual reports must be submitted on paper for now.
Rebecca Villalva, team leader for the TCEQ stormwater team, told the Water Quality Advisory Work Group that the 2024 Phase 2 MS4 general permit (TXR‑40,000) was renewed on Aug. 15, 2024, and that MS4s had until Feb. 11, 2025 to submit renewal or new applications electronically through the Texas Net MS4 system developed with EPA.
"We received over 600 applications," Villalva said, and TCEQ has approved 145 renewal notices of intent (NOIs), placed 489 submissions on hold pending review and is actively reviewing 126 of those. She added that 36 NOIs currently cannot be processed because the Net MS4 system is blocking TCEQ staff from using approval/deny buttons; TCEQ has opened a ticket with EPA to resolve those errors.
The division emphasized that the Net MS4 workflow treats many review comments in the system as a denial that includes a comment field; applicants can correct deficiencies and resubmit while TCEQ honors the original electronic application date for federal reporting to ISES. Villalva said the approval email will include a certificate of authorization with links to print an approval letter.
On reporting, Villalva said an EPA pause in development means the planned Texas annual‑reporting module for MS4 Phase 2 remains unavailable. "Due to limited EPA resources, the development of our Texas annual report module in that MS4 system has been paused," she said, and TCEQ will notify permittees when the module is available. Until then, permittees still operating under the 2019 or newly approved 2024 permit cycles must submit annual reports on paper using the applicable template.
Villalva explained the 2024 permit uses a calendar-year reporting period (Jan. 1–Dec. 31). When approval occurs mid‑year, TCEQ will treat the approval date as the end of the old permit cycle and the start of the new one; permittees may need to submit a short final report covering the prior cycle and a partial report for the remainder of the calendar year. For implementation of required best‑management practices (BMPs) during a partial reporting year, she said TCEQ expects prorated implementation (for example, one quarter of an annual metric if the permittee is under the permit for one quarter).
TCEQ urged permittees with unusual fiscal-year or timing questions to contact the division's SWGP mailbox for case‑specific guidance.
Next steps: applicants should monitor the TCEQ Water Quality Advisory Work Group webpage for updates and the agency will announce when the electronic annual reporting module is restored. TCEQ said it will continue processing Net MS4 applications as EPA addresses system tickets.

