Relating to the construction of certain concrete plants under a standard permit.

Contracts

• EPC & Construction Agreements: Review all Master Service Agreements (MSAs) and Engineering, Procurement, and Construction (EPC) contracts. You must insert indemnity clauses: if a contractor’s delay forces you to file for a permit extension, and that extension triggers a mandatory facility upgrade, the contractor must bear the cost of the retrofit.
• Force Majeure: Redefine "Change in Law" provisions. Ensure that a regulatory requirement to redesign a plant due to a lapsed construction window allows you to renegotiate or terminate land and supply contracts.

Hiring/Training

• Project Management: Project managers must be trained on the new definition of "Regulatory Risk." A construction delay is no longer just a timeline issue; it is a design compliance risk.
• Environmental Compliance: Staff must actively monitor TCEQ standard permit amendments. If the standard permit changes, your unbuilt projects are immediately at risk of obsolescence.

Reporting & Record-Keeping

• Proof of Commencement: You must rigorously document the "Start of Construction" to avoid being classified as a delayed project. Maintain dated site logs, geotagged photography of foundation work, and invoices for on-site materials.
• Design Version Control: Maintain a comparative analysis file. You must be able to instantly identify the difference between your *authorized* design and the *current* standard permit requirements to calculate the financial exposure of an extension request.

Fees & Costs

• Capital Expenditures: While there are no new state fees, the operational cost impact is potentially high. If TCEQ mandates compliance with a newer standard permit, you may be forced to purchase advanced filtration systems or scrubbers that were not in your original budget.
• Sunk Costs: Engineering plans for unbuilt facilities may become total write-offs if the new standards render the design fundamentally non-compliant.