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Signed Into Law
Signed June 20, 2025Effective 2025-06-20
HB2080

Regular Session

Relating to the review of the duties of a groundwater conservation district by the Texas Commission on Environmental Quality.

Government Affairs & Regulatory Compliance Analysis

HB2080: Government Affairs Overview

Effective immediately, HB2080 restructures the administrative review process for challenging Groundwater Conservation District (GCD) performance, formalizing the "Review Panel" structure and creating a statutory mechanism to extend dispute resolution timelines by four months. This law directly impacts agribusiness, industrial water users, and developers currently filing or contemplating petitions against a GCD for failure to enforce management plans.

Rep. Stan Gerdes·House Bill·Regular Session

Moderate
Low Cost
Effective:2025-06-20
Business Impact

Who HB2080 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: moderate

Notable regulatory updates (effective 2025-06-20). Consider how these changes may affect your operations.

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Water

Affected business types:

  • Water utilities
  • Wastewater treatment facilities
  • Municipal water districts
  • Agricultural water users
View all water legislation

Key Operational Considerations

  • 1Panel Service: Staff members appointed to panels must be trained that while they are exempt from Open Meetings Act quorum rules, their communications with the recording secretary are public records.

Estimated Cost Impact

lowMinimal cost impact anticipated.

Enforcing Agencies

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HB2080
Relating to the review of the duties of a groundwater conservation district by the Texas Commission on Environmental Quality.
Moderate Urgency
Passed with Opposition
House Vote118 - 1
YEA
99% in favor119 voting
Senate Vote28 - 3
YEA
90% in favor31 voting
4
Total Opposition Votes
Cost Impact
Low
Effective
2025-06-20
Enforcing Agencies
TCEQTWDB
Primary Author: Rep. Stan Gerdes
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: June 20, 2025 (Immediate).
  • Compliance Deadline: Immediate. The new procedures apply to any petition for inquiry filed with the TCEQ on or after June 20, 2025. Petitions filed prior to this date remain under the former law.
  • Agency Rulemaking: While the statute is self-executing, expect TCEQ to update internal procedural guidance regarding the appointment of "disinterested" recording secretaries and the specific format for expense reimbursement requests.

Immediate Action Plan

  • Audit Active Disputes: Determine if any planned petitions were filed before June 20, 2025. If not, revise your litigation timeline to account for the new Review Panel procedures.
  • Update Docketing Systems: Configure legal calendar alerts to capture the new 7-day notice window for TCEQ/Review Panel hearings.
  • Prepare for Delays: If filing a petition, build a 120-day buffer into your project development timeline to account for the TWDB technical review loop.
  • Segregate Communications: If involved in a panel, instruct staff to communicate strictly through the official recording secretary to maintain a clear PIA trail, but assume all such communication is public.

Operational Changes Required

Contracts

  • Legal & Consulting Agreements: If your organization is the petitioner, review engagement letters with outside counsel to account for a potentially longer engagement period (up to 120 additional days).
  • Conflict Waivers: If an employee or officer of your company is appointed to a Review Panel, execute specific conflict waivers and separate engagement letters for any outside counsel advising them personally, ensuring your proprietary data remains protected.

Hiring/Training

  • Legal Team Training: In-house counsel and compliance officers must update their docketing protocols. The notice window for public meetings/hearings is now 7 days (previously subject to standard Open Meetings Act lead times).
  • Panel Service: Staff members appointed to panels must be trained that while they are exempt from Open Meetings Act quorum rules, their communications with the recording secretary are public records.

Reporting & Record-Keeping

  • Expense Verification: Panel members must submit a "verified statement" with physical receipts to the TCEQ Executive Director to receive reimbursement. Standard per diems do not apply; this is a reimbursement-only model.
  • Public Information Act (PIA): Treat all submissions to the Review Panel as immediately discoverable. The recording secretary’s records are explicitly subject to Chapter 552 (Public Information Act).

Fees & Costs

  • Litigation Budgeting: There are no new filing fees. However, businesses must budget for increased legal fees associated with the 120-day automatic extension if the panel requests technical assistance from the Texas Water Development Board (TWDB).

Strategic Ambiguities & Considerations

  • The "Technical Assistance" Delay: The law allows the Review Panel to request technical assistance from the TWDB, which triggers a 120-day deadline extension. The statute does not define a materiality threshold for this request. Warning: Anticipate that GCDs under review will pressure panels to make minor technical requests specifically to trigger this four-month delay.
  • "Disinterested Person" Standard: The recording secretary must be a "disinterested person." The statute lacks a definition for this term. Until TCEQ clarifies via rulemaking or precedent, this appointment is a primary target for procedural challenges if the secretary has any tangential link to the parties involved.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Jan 24, 2025
Passed House
May 16, 2025
Passed Senate
May 26, 2025
Signed
Jun 20, 2025
Effective
Jun 20, 2025
TopicsSpecial Districts & AuthoritiesSpecial Districts & Authorities--groundwater Conserve Dist.Special Districts & Authorities--water & UtilityWaterWater--conservationEnvironmental Quality, Texas Commission OnPublic NoticeRecords Management
03

House Authors

Rep. Stan GerdesRepublican · Primary Author
Joint Authors

Senate Sponsor

Sen. Charles PerryRepublican · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

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More from Rep. Stan Gerdes

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Related by Topic

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Quick Reference

Frequently Asked Questions

Common questions about HB2080

Q

What does Texas HB2080 do?

Effective immediately, HB2080 restructures the administrative review process for challenging Groundwater Conservation District (GCD) performance, formalizing the "Review Panel" structure and creating a statutory mechanism to extend dispute resolution timelines by four months. This law directly impacts agribusiness, industrial water users, and developers currently filing or contemplating petitions against a GCD for failure to enforce management plans.

Q

Who authored HB2080?

HB2080 was authored by Texas Representative Stan Gerdes during the Regular Session.

Q

When was HB2080 signed into law?

HB2080 was signed into law by Governor Greg Abbott on June 20, 2025.

Q

Which agencies enforce HB2080?

HB2080 is enforced by Texas Commission on Environmental Quality (TCEQ) and Texas Water Development Board (TWDB).

Q

How significant are the changes in HB2080?

The regulatory priority for HB2080 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of HB2080?

The cost impact of HB2080 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does HB2080 address?

HB2080 addresses topics including special districts & authorities, special districts & authorities--groundwater conserve dist., special districts & authorities--water & utility, water and water--conservation.

Q

What are the key dates for HB2080?

Key dates for HB2080: Effective date is 2025-06-20. Consult with legal counsel regarding applicability.

Need Strategic Guidance on This Legislation?

JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.

Legislative data provided by LegiScanLast updated: January 11, 2026