How to Prepare Your Dust Control Plan for TCEQ Compliance

The Texas Commission on Environmental Quality (TCEQ) is scheduled to propose updates to Chapter 309 and Chapter 210 on April 30, 2026. These changes implement SB 1145 and transfer permitting authority for land application of treated produced water (PW) from the Railroad Commission of Texas (RRC) to TCEQ. Dust suppression on lease roads, well pads, and construction sites is explicitly recognized as a beneficial use under the new framework.

For operators and EPC teams working across the Permian Basin — in Midland, Odessa, Pecos, and in counties including Reeves, Ward, Loving, Ector, and Andrews — this rulemaking is not abstract. It will directly influence how dust control plans are developed, documented, and executed in the field. Preparing now can help avoid compliance gaps and reduce operational disruptions as the rules move toward adoption — targeted for August 2026.

Understanding the Key Changes

Practical Steps to Prepare Your Dust Control Plan

1. Assess Current Suppression Practices

Review how dust control is currently managed on your sites. Document water sources (including PW), application frequency, re-application triggers during high-wind periods, and any observed performance issues such as equipment wear or visibility impacts. Note differences between early earthwork phases and later construction stages.

2. Evaluate Water Sources and Treatment Needs

Determine whether your current PW or other water sources will meet the new secondary treatment standards for land application. Consider logistics: fill-up locations, truck rotation schedules, and coordination with shift changes or heavy traffic periods to minimize gaps in coverage.

3. Document Site-Specific Conditions

Gather data on soil types, groundwater proximity, drainage patterns, wind patterns, and typical dust events. This information will support the site-specific technical reports required under the new rules — and it's data most active sites already have in some form.

4. Compare Suppression Methods

Evaluate plain or treated PW spraying versus commercial suppressants. Consider total cost of ownership: material costs, re-application frequency, labor, equipment impact, and how each option aligns with TCEQ monitoring and reporting expectations. Commercial products often provide longer residual control, which can reduce re-application needs during sustained wind events.

5. Plan for Monitoring and Record-Keeping

Establish simple logging procedures for application rates, weather conditions, and re-application events. This documentation will be important for compliance once the rules are finalized. Starting now means you'll have a baseline record before the rules take effect.

6. Coordinate with Suppliers and Partners

Reach out to dust suppression providers who can supply technical data, performance documentation, or PW-compatible blends. Many have experience supporting permit applications and can provide guidance on best management practices that align with the new framework.

Field Considerations from Permian Sites

In practice, dust control on active sites requires consistent coverage during high-wind periods to maintain visibility and safety. Gaps in spraying can lead to rapid dust return, and equipment buildup is a common challenge regardless of method. EPC projects often face the highest demands during early earthwork, while long-term operator setups allow for more permanent solutions over time. The new TCEQ rules add a compliance layer that many teams are already incorporating into their planning.

Operators and EPC teams across the Permian Basin — including active development areas in Midland and Ector Counties, the Delaware Basin counties of Reeves and Ward, and southeastern New Mexico's Lea and Eddy Counties — are among those most directly affected. If you're evaluating dust control options or preparing for TCEQ compliance, the resources and supplier connections on this site are built specifically for your operating environment.