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Contractors say daily dewatering inspection requirements are impractical; suggest alternative verification approach
Summary
During the TCEQ stakeholder meeting, industry representatives said proposed daily dewatering documentation and rate estimation are impracticable for intermittent dewatering; they recommended initial verification before the first day and targeted ongoing oversight only for multi‑day dewatering events.
Contractors and consultants at the TCEQ stakeholder meeting raised persistent implementation concerns about proposed dewatering observation and documentation requirements in the draft CGP renewal.
Kevin Laws of LAR Homes said the current wording that requires damaged or disabled erosion controls to be "replaced or corrected immediately upon discovery" is impracticable and financially burdensome for many permittees, who may not have labor or contractors available on short notice. "Determining intentionality is very difficult ... I will say permittees do not have labor and materials to comply with that and to do so would be financially burdensome," Laws said.
Why it matters: Dewatering activities are often intermittent, short‑notice and driven by precipitation or groundwater encounters; inspectors and third‑party consultants typically visit sites at scheduled times and may not observe brief dewatering events or be able to estimate discharge rates accurately.
Suggested compromise: Several commenters proposed a pragmatic alternative: conduct an initial qualified inspection and verification prior to the first day of dewatering for multi‑day events, and require ongoing observations only for dewatering that continues beyond a single day. Commenters also recommended a requirement to cease pumping when pollutant indicators are observed and to document rationale and corrective actions in the SWIP.
Agency response: TCEQ staff acknowledged the comment stream and said the agency will consider comments and precedent (including EPA CGP language and other state permits) to balance enforceability with practicability. Staff invited stakeholders to submit concrete alternative language and suggested examples to help craft workable requirements.
Next step: Stakeholders said they will submit written comments and examples to the TCEQ stormwater inbox by the stated deadline to help shape the dewatering language.
