As part of its process to amend its compliance history rules (30 TAC 60), TCEQ recently released a list of expected scores from the state’s pollution sources.
Because of computer programming limitations during rule development, scores do not reflect all aspects of the proposed formula. They represent approximate numbers using a simplified model. Limitations include:
- The scores were generated using data from September 2006–August 2011. Upon rule adoption, new scores will be generated using data from September 1, 2007–August 31, 2012.
- The scores do not accurately reduce points for compliance with administrative orders. Under the proposed rule, 2 years after the effective date of an order, if an entity is compliant with all ordering provisions and has resolved all violations, the points attributable to that order will be reduced. The reduction will be 25 percent for year 3, 50 percent for year 4, and 75 percent for year 5.
- Points awarded for “small entities” are not completely reflective of the proposed rule.
- Reductions for voluntary programs are not completely reflective of the proposed rule. The proposed rule allows for a maximum 25 percent reduction of compliance history points for implementing voluntary programs.