There are currently an estimated 155 plastics manufacturers and molders in the state of Texas, but current state laws are too weak to prevent them from discharging these plastics into waterways. This has led to extensive plastic pollution in state waters, not the least of which are the millions of plastic pellets discharged by Formosa Plastics into Lavaca Bay.

The Texas Commission on Environmental Quality ("TCEQ") is in the process of revising its surface water quality standards and procedures, and as part of that process the agency is proposing changes to the standards and procedures so that the discharge of pre-production plastics (a.k.a. "nurdles" as well as powders and flakes) becomes specifically regulated.

TCEQ is proposing to establish a prohibition on discharges of plastic as part of stormwater and wastewater permits, meaning no plastic will be allowed to be discharged, and that is a big step forward. However, there are details of the standards and procedures for implementation that need strengthened to ensure that the zero discharge intent is achieved.

Please send a letter to TCEQ administrators to let them know you support a strong set of standards and well-designed implementation procedures to ensure that the intent of the prohibition on the discharge of plastics is upheld.