By: Julie Nahrgang

As Executive Director of the Water Environment Association of Texas (WEAT) and the Texas Association of Clean Water Agencies (TACWA), I have the privilege of representing more than 16 million Texas ratepayers and the dedicated professionals who design, build, operate, and regulate our state’s clean water infrastructure. Recently, I had the opportunity to testify before state leadership about the urgent needs facing Texas' wastewater systems. With aging infrastructure, soaring population growth, and tightening regulatory requirements, now is the time for a Texas-sized investment – not only to protect public health and the environment but also to sustain the economic miracle that makes our state thrive.

Here is what I shared:

Good afternoon Chairman Harris, Vice Chairman Martinez, and esteemed committee members. My name is Julie Nahrgang, and I am here on behalf of the Water Environment Association of Texas (WEAT) and Texas Association of Clean Water Agencies (TACWA) where I serve as Executive Director. I appreciate the opportunity to provide comments on the state of Texas water. WEAT and TACWA are mission driven nonprofit organizations that empower water professionals to educate, enhance, and advocate for Clean Water across Texas. Between the individual members and organizational municipal members, WEAT/ TACWA represent over 16 million Texas rate payers. Our members include engineers, plant managers, operators, municipal directors, scientists, attorneys, manufacturers and reps, and all of the other clean water professionals that play a role in the design, build, operation, and regulation of the infrastructure that turns wastewater into clean water. I am here today to talk about the infrastructure that treats our wastewater and challenges and opportunities thereof. And to be clear, the needs for clean water funding in Texas are immense. There are urgent, here and now needs to address aging and deteriorating infrastructure and meet Texas’ booming population growth. We also have emerging contaminants on the regulatory horizon that will require large investments in new treatment technologies as well as increasingly lower nutrient limits in TPDES discharge permits for phosphorus and nitrogen, which require large-scale capital improvement projects. ASCE recently gave wastewater infrastructure a grade of D-. Wastewater infrastructure is tied with levees in receiving the worst infrastructure grade in Texas. In the larger conversation about water infrastructure funding and investment, wastewater infrastructure needs can sometimes be under-discussed or go unrecognized. There’s a lot of talk about leaky pipes, water loss, and main breaks. Leaky pipes aren’t just on the drinking water side. When we talk of fixing leaky pipes and water loss, let’s consider that in the context of our collection systems and sewage mains, which are the pipes under our feet that move wastewater to our treatment plants.

How we treat our wastewater and the state of our wastewater infrastructure is a water supply issue and can enhance or threaten the Texas miracle.

According to TCEQ data, in 2023 Texas experienced over 3,700 sanitary sewer overflows or SSOs. And in 2024, Texas experienced over 4,600 SSOs. An SSO is an unauthorized discharge of untreated wastewater into the environment. To put this in terms we frequently use, SSOs ARE leaky pipes, SSOs ARE water loss, and SSOs are main breaks. They are also violations of federal law and pose a human and environmental health risk. These SSOs are caused by a number of factors including but not limited to the age and health of our wastewater infrastructure. And when a water/ wastewater system experiences a large number of SSOs across a period of time, the EPA will step in and negotiate a federal Clean Water Consent Decree with the city. Currently, Texas has 5 cities in various stages of Clean Water Federal Consent Decrees. San Antonio will soon be rolling off. Corpus Christi, Tyler, and Houston are currently under a Consent Decree and Baytown is finalizing their settlement. With 5 cities, Texas leads the nation in the number of cities under or in active negotiations for a Federal Clean Water Consent Decree. This is not a category where Texas should be leading. We don’t want to be the first worst.

We need a one-time Texas-sized investment and dedicated annual funding with maximum allocation flexibility by the TWDB to ensure wastewater infrastructure receives meaningful funding.

You may have heard people say that 1600 folks are moving to Texas each day and none of them are bringing any water with them. Let’s extend that and be explicit and say none of them are bringing any infrastructure to treat the additional wastewater produced either.

A good deal of that population growth is because of Texas’ open business policy lending to the Texas miracle. Many factories, including chip manufacturers and other tech producers dot the Texas landscape. The industrial wastewater these factories produce is monitored by pretreatment programs at the municipalities receiving and treating industrial waste streams. Our water supply sources can be protected or degraded by the quality of our wastewater infrastructure and the availability of a skilled workforce.

For Texas to continue to be open for business while protecting human health and the environment, there needs to be a Texas-sized investment in our wastewater infrastructure as well as a statewide planning initiative.

I’m thrilled that Texas is on the precipice of making a truly generational investment in water and considering a dedicated annual funding source. And when thinking through how to allocate that money,I encourage you to ensure that our wastewater infrastructure receives badly needed funding. Because right now, today's needs vastly outstrip the available funding.

And the reality is, there are limited state funding options for wastewater infrastructure. The primary funding bucket for wastewater infrastructure under the Texas Water Fund administered by the TWDB is the Clean Water State Revolving Fund, or Clean Water SRFs. In 2024 approximately $460,000,000.00 was given out in Clean Water SRFs. That $460M represents only 14% of the funding requests received. As you heard in previous testimony, SRFs are at least 9xs oversubscribed. And when the IIJA money that Texas received and put towards SRFs runs out next year, there will be even less SRF money available for clean water funding.

The DFund, under the Texas Water Fund can also provide funding for wastewater infrastructure, but that has so far been very limited. In 2024, the TWDB committed $47.5M through the DFund for water, wastewater, and flood control, which is nearly twice as much as 2023 but just a drop in the bucket.

SWIFT can fund some wastewater infrastructure projects if they come under the banner of reuse and are in the State Water Plan. But only 4% of the most recent SWP is composed of reuse.

So, under the TWF, the primary source of wastewater funding comes from CWSRFs, some from SWIFT if it’s reuse, and even a smaller portion from DFund. There is a gap in state funding availability for wastewater infrastructure. There are leaky pipes, there’s aging and deteriorating infrastructure, there’s massive growth in population and industry. And as the Texas legislature sits on the precipice of making a Texas-sized investment in water, I encourage you to ensure that investment is allocated in a way that also addresses today’s and tomorrow’s wastewater infrastructure needs.

Furthermore, to ensure a Texas-sized investment of at least $2.5 billion and a dedicated revenue stream of at least $1 million is efficiently and effectively distributed, we must also invest in our human infrastructure and the agencies that push funding out the door and monitor the drinking water and wastewater infrastructure. WEAT fully supports TWDB and the TCEQ’s legislative appropriations requests with exceptional items. These agencies are key to keeping our water/wastewater infrastructure functioning as intended. Additional Investment in water must mean additional investment in the agencies that work with our water systems.

We have urgent, here and now funding needs for Texas’ wastewater infrastructure. We currently have a real lack of wastewater funding options. And we also have a lack of statewide and holistic planning for our wastewater infrastructure. We need to plan for growth and encourage regionalization and take advantage of economies of scale. We prioritize planning for water supply and floods, it’s now time to prioritize a Texas Clean Water Plan. And just to say it again, with this historic water funding legislation, we need to ensure that we allocate it in a way that also benefits wastewater.

I want to thank Chairman Harris, Vice Chairman Martinez, and committee members for the opportunity to discuss wastewater infrastructure funding and planning. And I'm happy to answer any questions if there are any.