Regular Session
Government Affairs & Regulatory Compliance Analysis
HB609 mandates the Texas Commission on Environmental Quality (TCEQ) to authorize in-water cleaning of oyster mariculture gear starting September 1, 2025. This creates a new operational efficiency for Cultivated Oyster Mariculture (COM) permit holders but imposes strict liability for the use of any cleaning additives or chemicals; using anything other than ambient water constitutes a violation of the Texas Water Code.
Rep. Cody Vasut·House Bill·Regular Session
This legislation has regulatory implications for the following Texas businesses and organizations:
Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.
Affected business types:
lowMinimal cost impact anticipated.
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JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with this legislation
Master Service Agreements (MSAs) with third-party cleaning or diving vendors must be amended to explicitly prohibit the possession or use of soaps, detergents, or chemical additives. Include indemnity clauses holding the vendor liable for administrative penalties resulting from their use of unauthorized agents.
Field crews must undergo mandatory training on the "No Chemical/No Soap" restriction. Disciplinary policies should be updated to classify the use of cleaning agents during water-based maintenance as a terminable offense, as this poses a direct risk to the facility's operating permit.
Maintain vessel logs recording the specific GPS coordinates, time, and method of cleaning to prove operations occurred within the permitted footprint. While no specific new form is mandated yet, prepare to log visual water quality inspections (turbidity) as a likely condition of the forthcoming General Permit.
There are no new statutory fees associated with this authorization. However, violations of the chemical prohibition trigger standard TCEQ administrative penalties, which vary based on the severity of the unauthorized discharge.
JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.
Schedule a ConsultationInformation 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.
This bill's path through the Texas Legislature
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Common questions about HB609
HB609 mandates the Texas Commission on Environmental Quality (TCEQ) to authorize in-water cleaning of oyster mariculture gear starting September 1, 2025. This creates a new operational efficiency for Cultivated Oyster Mariculture (COM) permit holders but imposes strict liability for the use of any cleaning additives or chemicals; using anything other than ambient water constitutes a violation of the Texas Water Code.
HB609 was authored by Texas Representative Cody Vasut during the Regular Session.
HB609 was signed into law by Governor Greg Abbott on June 20, 2025.
HB609 is enforced by Texas Commission on Environmental Quality (TCEQ) and Texas Parks and Wildlife Department (TPWD).
The regulatory priority for HB609 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB609 is estimated as "low". This may vary based on industry and implementation requirements.
HB609 addresses topics including environment, environment--water, parks & wildlife, parks & wildlife--general and aquaculture.
Key dates for HB609: Effective date is 2025-09-01. Rulemaking: Must amend the General Permit for Aquaculture to authorize in-water cleaning of oyster structures and establish specific permit conditions in consultation with TPWD. (2025-09-01). Consult with legal counsel regarding applicability.
HB609 establishes the following penalties: administrative penalty of Variable (Standard TCEQ administrative penalties) for Cleaning structures with any soap, chemical, or additive; cleaning structures outside the authorized permit location; or using water other than from the location.. Consult with legal counsel for specific applicability to your situation.
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.
