2025-011 Rainbow Valley November 26, 2024 Report No. 2025-011
INFORMAL STAFF REPORT
TO MAYOR AND CITY COUNCIL
SUBJECT:
The City of Denton received notice regarding an application for Texas Commission on
Environmental Quality (TCEQ) Texas Pollutant Discharge Elimination System (TPDES) Permit
No. WQ0016624001 to authorize the discharge of treated wastewater at a volume not to exceed a
daily average flow of 950,000 gallons per day. This permit is required to accommodate a small
wastewater reclamation plant for a proposed development in the area. The discharge point of the
proposed facility is located off Rainbow Valley Road
EXECUTIVE SUMMARY:
On November 13,2024,staff met to discuss the impact of the TPDES permit application.Important
points discussed during the meeting include:
• Once provisional approval is awarded by the Executive Director of TCEQ affected parties
have a very short time to protest, 30 days.
• Residents of the Whitehawk and Rainbow Valley communities have voiced concerns
about the location and proposed discharge point of the facility negatively impacting
access to, and water quality of, their community.
• This project is located just outside of the City of Denton's Certificate of Convenience and
Necessity (CCN).
• City of Denton has established Master Plans that envision service in this project and
eliminate the need for the proposed facility. Regionalization of wastewater services is also
discussed regularly at meetings with developers to avoid multiple small facilities managed
by different entities.
• Environmental Services & Sustainability Department reviewed the permit
application and identified that discharge limits in the permit are high for some
pollutants and could pose a risk to the City of Denton watershed.
• General development that will likely come with creation of new wastewater plants
will cause non-point source pollution. Clear Creek is on the 303d list as concerned for
bacteria. The situation could progress to a regulatory requirement with a Total Maximum
Daily Load(TMDL) and Implementation Plan. The Total Maximum Daily Load(TMDL)
is a scientifically derived target for water quality, and an Implementation Plan (I-Plan) is
a plan to reduce pollution and improve water quality. A TMDL could impact the permit
limitations associated with Denton's planned Clear Creek wastewater treatment plant.
• The City of Denton holds the primary Municipal Storm Sewer System (MS4)Permit
in the area.Even if the urban area expands with the 2030 census,TCEQ rules allow newly
permitted plants a waiver from stormwater management requirements if their throughput
is under 1 MGD. If the new plants do not meet the definition of regulated entity (i.e.,
qualify for the waiver), stormwater management costs could fall to the cities of
Denton and Sanger as regulated entities.
• Water Utilities Staff are currently developing a policy and work session presentation to
present to City Council on December 17, 2024.
November 26, 2024 Report No. 2025-011
• Staff will also include both a staff recommendation and an ordinance to be voted on as an
Individual Consideration Item to ensure that a policy is in place before the 30-day protest
deadline begins.
DISCUSSION:
How will the city balance the desire for regionalization of water and wastewater treatment and
distribution facilities vs. developers pushing for solutions that are tailored to the needs of their
development and nothing further? What environmental impacts will result from multiple smaller
wastewater treatment facilities managed by different entities as opposed to larger centralized
facilities run by Denton Water Utilities that are sized to accommodate the needs of the entire
region?How will the City balance its support of growth in the area with its commitment to protect
its watershed?
CONCLUSION:
As North Central Texas continues to grow rapidly,the use of applications such as this will become
more common. It is crucial for the City to establish a policy that allows staff to initiate the protest
process as soon as possible. This policy should include a mechanism for keeping the City Council
informed about the number of applications in our region, as well as staff evaluations regarding the
impact and necessity of a protest.
Additionally, the City must ensure that discharges from any new wastewater treatment facilities
into Clear Creek,Milam Creek,Hickory Creek, and Pecan Creek do not affect their designated use
criteria. Furthermore, these discharges must not have any adverse environmental impact on the
watershed or interfere with the City's plans to regionalize wastewater treatment to safeguard the
watershed's integrity.
ATTACHMENTS:
TCEQ Notice
STAFF CONTACT:
Stephen D. Gay—Water Utilities and Street Operations General Manager, Ext. 8086
Stephen.gay@cityofdenton.com
REOUESTOR:
Staff initiated.
PARTICIPATING DEPARTMENTS:
Water Utilities, Environmental Services & Sustainability, City Attorney's Office
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
TE
NOTICE OF RECEIPT OF APPLICATION AND
INTENT TO OBTAIN WATER QUALITY PERMIT
PROPOSED PERMIT NO. WQ0016624001
APPLICATION. Sanger Laguna Azure LLC and James N. Horn, 2101 Cedar Springs Road, Suite
700, Dallas, Texas 75201, have applied to the Texas Commission on Environmental Quality
(TCEQ) for proposed Texas Pollutant Discharge Elimination System (TPDES) Permit No.
WQ0016624001 (EPA I.D. No. TX0146609) to authorize the discharge of treated wastewater
at a volume not to exceed a daily average flow of 950,000 gallons per day. The domestic
wastewater treatment facility will be located approximately 0.77 miles northwest of the
intersection of Farm-to-Market Road 2153 and Farm-to-Market Road 2164, near the city of
Sanger, in Denton County, Texas 76266. The discharge route will be from the plant site to an
unnamed tributary, thence to another unnamed tributary, thence to Clear Creek, thence to
Elm Fork Trinity River. TCEQ received this application on September 16, 2024. The permit
application will be available for viewing and copying at Sanger Public Library, 501 Bolivar
Street, Sanger, in Denton County, Texas prior to the date this notice is published in the
newspaper. The application, including any updates, and associated notices are available
electronically at the following webpage:
http s://www.tc e g.texas.gov/p ermitting/was tewater/p ending-permits/tp de s-applic ations.
This link to an electronic map of the site or facility's general location is provided as a public
courtesy and not part of the application or notice. For the exact location, refer to the
application.
https://gisweb.tceg.texas.gov/LocationMapper/?marker=-97.1313 88,3 3.34 5&level=18
ALTERNATIVE LANGUAGE NOTICE.Alternative language notice in Spanish is available at:
http s://www.tceg.texas.gov/permitting/wastewater/pending_13ermits/tpde s-applic ations.
El aviso de idioma alternativo en espanol esta disponible en
http s://www.tceg.texas.gov/permitting/wastewater/pending_13ermits/tp de s-applic ations.
ADDITIONAL NOTICE. TCEQ's Executive Director has determined the application is
administratively complete and will conduct a technical review of the application. After
technical review of the application is complete, the Executive Director may prepare a draft
permit and will issue a preliminary decision on the application. Notice of the Application
and Preliminary Decision will be published and mailed to those who are on the county-
wide mailing list and to those who are on the mailing list for this application. That notice
will contain the deadline for submitting public comments.
PUBLIC COMMENT / PUBLIC MEETING. You may submit public comments or request a
public meeting on this application. The purpose of a public meeting is to provide the
opportunity to submit comments or to ask questions about the application. TCEQ will hold a
public meeting if the Executive Director determines that there is a significant degree of public
interest in the application or if requested by a local legislator. A public meeting is not a
contested case hearing.
OPPORTUNITY FOR A CONTESTED CASE HEARING. After the deadline for submitting
public comments, the Executive Director will consider all timely comments and prepare a
response to all relevant and material, or significant public comments. Unless the application
is directly referred for a contested case hearing, the response to comments, and the
Executive Director's decision on the application, will be mailed to everyone who
submitted public comments and to those persons who are on the mailing list for this
application. If comments are received, the mailing will also provide instructions for
requesting reconsideration of the Executive Director's decision and for requesting a
contested case hearing. A contested case hearing is a legal proceeding similar to a civil trial
in state district court.
TO REQUEST A CONTESTED CASE HEARING, YOU MUST INCLUDE THE FOLLOWING ITEMS
IN YOUR REQUEST: your name, address, phone number; applicant's name and proposed
permit number; the location and distance of your property/activities relative to the
proposed facility; a specific description of how you would be adversely affected by the
facility in a way not common to the general public; a list of all disputed issues of fact that
you submit during the comment period and, the statement "[I/we] request a contested
case hearing." If the request for contested case hearing is filed on behalf of a group or
association, the request must designate the group's representative for receiving future
correspondence; identify by name and physical address an individual member of the
group who would be adversely affected by the proposed facility or activity; provide the
information discussed above regarding the affected member's location and distance from
the facility or activity; explain how and why the member would be affected; and explain
how the interests the group seeks to protect are relevant to the group's purpose.
Following the close of all applicable comment and request periods, the Executive Director will
forward the application and any requests for reconsideration or for a contested case hearing
to the TCEQ Commissioners for their consideration at a scheduled Commission meeting.
The Commission may only grant a request for a contested case hearing on issues the
requestor submitted in their timely comments that were not subsequently withdrawn. If a
hearing is granted, the subject of a hearing will be limited to disputed issues of fact or
mixed questions of fact and law relating to relevant and material water quality concerns
submitted during the comment period.
MAILING LIST. If you submit public comments, a request for a contested case hearing or a
reconsideration of the Executive Director's decision, you will be added to the mailing list for
this specific application to receive future public notices mailed by the Office of the Chief
Clerk. In addition, you may request to be placed on: (1) the permanent mailing list for a
specific applicant name and permit number; and/or (2) the mailing list for a specific county.
If you wish to be placed on the permanent and/or the county mailing list, clearly specify
which list(s) and send your request to TCEQ Office of the Chief Clerk at the address below.
INFORMATION AVAILABLE ONLINE. For details about the status of the application, visit the
Commissioners' Integrated Database at www.tceg.texas.gov/goto/cid. Search the database
using the permit number for this application, which is provided at the top of this notice.