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Legal counsel explains fee reserve practice; says TWRA may not follow typical reserve rule

Agriculture & Natural Resources · April 20, 2026
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Summary

Doug Garrett of the Office of Legal Services told the panel that the typical regulatory fee reserve practice (about 2.5 times annual operating expenses) likely does not apply to TWRA, but acknowledged the agency would consider reducing fees if reserves accumulate.

Doug Garrett, representing the Office of Legal Services, told the subcommittee that many boards and commissions that set regulatory fees operate with a reserve guideline — typically about 2.5 times annual operating expenses — but he did not believe that mechanism directly applies to TWRA. Garrett said if TWRA accumulated a significant reserve from permit fees, the agency would likely explore fee reductions.

Garrett’s explanation was offered in response to a question about whether excess fee balances can be drawn down through administrative mechanisms. His comments framed a path for legislative or administrative follow‑up if revenue projections prove higher than agency needs.