Policy Issue Discussion For Sunset Commission ----- Review of Texas Natural Resource Conservation Commission
 

I. Name of person or organization:

Mary Kelly, Executive Director, Texas Center for Policy Studies, P.O. Box 2618, Austin, Texas 78768

II. Brief statement of the issue:

TNRCC should be collecting what location-specific pesticide use data there is currently available from other state agencies to fulfill its mission to protect surface and drinking waters and groundwater sources.

III. Brief discussion of the issue:

In order to adequately evaluate potential sources of contamination for surface and drinking waters and groundwater, TNRCC should be tapping into existing sources of data on pesticide use.  TDA has statutory authority to "call in" pesticide use records kept by commercial, non-commercial and private applicators.  Other governmental entities, such as TxDOT, cities, counties and school districts, are required to keep records of pesticide applications. These could be provided to TNRCC to assist in its assessment of threats to the State's water quality. TNRCC does not currently solicit this information for use in its evaluations.  (See Letter from TCPS to Steve Walden, et al., May 5, 1999, and Texas PIN, Realm of the Unknown: Pesticide Use in Texas, Ch. III, pp. 25-26, January 1999, attached.)

IV. Benefits of the recommended change:

TNRCC would obtain much of the data needed to fill current gaps in information necessary to perform Source Water Assessment Program (SWAP) analyses.  Additionally, this data would improve TNRCC?s ability to perform the analyses and allocation of pollutant loading in water bodies that are not meeting water quality standards, as required under Section 303 (d) of the federal Clean Water Act.  (See Texas PIN, Pesticides and Water Quality, Part I.C., January 1999, attached.)

V. Possible drawbacks of the recommended change:

The collection and organization of this data might impose some additional costs on TNRCC's program budgets.