Texas Commission on Environmental Quality and Guadalupe-Blanco River Authority v. National Wildlife Federation

CourtCourt of Appeals of Texas
DecidedMarch 10, 2026
Docket15-24-00050-CV
StatusPublished

This text of Texas Commission on Environmental Quality and Guadalupe-Blanco River Authority v. National Wildlife Federation (Texas Commission on Environmental Quality and Guadalupe-Blanco River Authority v. National Wildlife Federation) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Texas Commission on Environmental Quality and Guadalupe-Blanco River Authority v. National Wildlife Federation, (Tex. Ct. App. 2026).

Opinion

Affirmed and Opinion filed March 10, 2026.

In The

Fifteenth Court of Appeals

NO. 15-24-00050-CV

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY AND GUADALUPE-BLANCO RIVER AUTHORITY, Appellants V.

NATIONAL WILDLIFE FEDERATION, Appellee

On Appeal from the 98th District Court Travis County, Texas Trial Court Cause No. D-1-GN-20-007096

OPINION The Texas Commission on Environmental Quality (TCEQ) and the Guadalupe-Blanco River Authority (GBRA) appeal the district court’s judgment, reversing and remanding a TCEQ order that granted a water-rights permit to GBRA (the Order). Although we do not agree with all of the grounds on which the district court relied, we conclude that (1) the Order is affected by error of law because TCEQ erroneously interpreted Section 11.147(e-3) of the Water Code in determining that it was not required to assess the effects of GBRA’s proposed diversions of state water on fish and wildlife habitats, and (2) substantial rights of the appellee, National Wildlife Federation (NWF), have been prejudiced as a result. Consequently, we affirm the district court’s final judgment.

BACKGROUND Surface water in Texas is owned by the state and held in trust for the public. See Tex. Water Code §§ 11.021(a), .0235(a). The right to use state water may be acquired by appropriation for certain purposes as prescribed by Chapter 11 of the Water Code. See id. §§ 11.022, .023; see also id. § 5.013 (general jurisdiction of TCEQ). The right to appropriate state water is acquired by applying for and obtaining a permit from TCEQ. See id. § 11.121 (“[N]o person may appropriate state water or begin construction on any work designed for the storage, taking, or diversion of water without first obtaining permit from [TCEQ] to make the appropriation.”). TCEQ may grant the permit only if the application complies with certain procedural and substantive requirements. See id. §§ 11.124 (requirements for application to appropriate state water), .134 (action on application). In part, the applicant must demonstrate that the appropriation is sought for a beneficial use. See id. §§ 11.023, .134(3)(A).

In 2008, GBRA sought a water-rights permit from TCEQ in connection with a project referred to by the parties as the Mid-Basin Water Supply Project.1 Specifically, GBRA sought to divert water at one or more points along a 37-mile segment of the Guadalupe River (beginning near the city of Gonzales) for municipal and industrial purposes. In addition, GBRA sought approval of a plan to store some of the diverted water in “off-channel” reservoirs (meaning reservoirs not on the watercourse) for use when adequate flows from the river are not 1 GBRA is a conservation and reclamation district, created by the Legislature in 1935, pursuant to Article XVI, Section 59 of the Texas Constitution.

2 available. After receiving multiple requests for a contested-case hearing on the application, TCEQ referred the matter to the State Office of Administrative Hearings (SOAH). Some of the requestors, including NWF, were granted affected-party status and participated in the administrative proceedings.

Following the SOAH hearing, the administrative law judges (ALJs) issued a proposal for decision, recommending that TCEQ grant GBRA’s application. The ALJs also recommended that (1) TCEQ’s Water Availability Division conduct an additional environmental assessment of how construction and operation of the on- watercourse diversion structure would impact fish and wildlife habitats, and (2) TCEQ require GBRA to amend its permit before diverting any water to specify the exact locations of the off-channel reservoirs and the diversion sites.

On September 1, 2020, TCEQ signed the Order, granting GBRA’s water-use permit but rejecting the ALJ’s recommendations to conduct an additional assessment of fish and wildlife habitats and to require additional location information. The permit contained three authorizations: (1) the right to use and divert 75,000 acre-feet of water per year from the Guadalupe River; (2) the right to store up to 125,000 acre-feet of water in off-channel reservoirs in Gonzales County; and (3) an “exempt inter-basin transfer authorization” to use water from the Guadalupe River in nearby basins.

NWF timely filed a suit for judicial review. See Tex. Gov’t Code §§ 2001.171, .176(a). After conducting a hearing on the merits, the district court signed a final judgment, reversing the Order and remanding the matter to TCEQ for further proceedings. The district court clarified in a letter to the parties the reasoning for its ruling, stating that (1) TCEQ erred by failing to fully assess the effects on fish and wildlife habitats from GBRA’s proposed diversions; (2) TCEQ erred by failing to assess the effects of GBRA’s proposed off-channel reservoirs

3 on fish and wildlife habitats; (3) TCEQ’s approval of GBRA’s water-rights application, which did not identify the location of the diversion points and describe the proposed facilities, was arbitrary and capricious; and (4) the substantial rights of NWF have been prejudiced as a result of TCEQ’s improper administrative findings, inferences, conclusions, or decisions. TCEQ and GBRA perfected this appeal, challenging each of the four grounds on which district court relied.

STANDARD OF REVIEW

Judicial review of an administrative order following a contested-case proceeding is governed by the substantial-evidence rule, which is found in Section 2001.174 of the Texas Administrative Procedure Act (APA). See Tex. Gov’t Code § 2001.174; see Mosley v. Texas Health & Human Servs. Comm’n, 593 S.W.3d 250, 258 (Tex. 2019) (explaining that APA is “generally applicable to all state agencies and processes for judicial review of their decisions”). Under this rule, a court must reverse or remand an agency decision if (1) “substantial rights of the appellant have been prejudiced,” and (2) that prejudice is a result of “administrative findings, inferences, conclusions, or decisions” that are

(A) in violation of a constitutional or statutory provision; (B) in excess of the agency’s statutory authority; (C) made through unlawful procedure; (D) affected by other error of law; (E) not reasonably supported by substantial evidence considering the reliable probative evidence in the record as a whole; or (F) arbitrary or capricious or characterized by abuse of discretion or clearly unwarranted exercise of discretion.

4 Tex. Gov’t Code § 2001.174.

Under the substantial-evidence rule, the agency’s findings, inferences, conclusions, and decisions are presumed to be supported by substantial evidence, and the burden is on the contestant to demonstrate otherwise. Texas Comm’n on Env’t Quality v. Maverick Cnty, 642 S.W.3d 537, 547 (Tex. 2022); Upper Trinity Reg’l Water Dist. v. Nat’l Wildlife Fed’n, 514 S.W.3d 855, 861 (Tex. App.— Houston [1st Dist.] 2017, no pet.). Whether the contestant has met this burden is a question of law, Dyer v. Texas Comm’n on Env’t Quality, 646 S.W.3d 498, 505 (Tex. 2022), and on review, we focus on the agency’s decision without deference to the district court’s judgment, Texas Dep’t of Pub. Safety v. Alford, 209 S.W.3d 101, 103 (Tex. 2006) (per curiam).

To the extent our review requires us to interpret the Water Code and administrative rules promulgated by TCEQ, these issues present questions of law, which we address de novo. Maverick Cnty., 642 S.W.3d at 544 (citing Railroad Comm’n of Tex. v. Texas Citizens for a Safe Future & Clean Water, 336 S.W.3d 619, 624 (Tex. 2011)).

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Texas Commission on Environmental Quality and Guadalupe-Blanco River Authority v. National Wildlife Federation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-commission-on-environmental-quality-and-guadalupe-blanco-river-texapp-2026.