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State Sen. Campbell urges TCEQ to deny Guajolote Ranch permit, citing environmental, scientific, procedural concerns

Nov. 14, 2025 – Texas state Sen. Donna Campbell, R-New Braunfels, sent a strongly worded letter to Texas Commission on Environmental Quality Chairwoman Brooke Paup, urging denial of a wastewater permit for the proposed controversial Guajolote Ranch development of Lennar Corp. in northwest Bexar County.

“This proposal threatens groundwater integrity, endangered species habitat and public health, while disregarding TCEQ’s statutory duties under state and federal law,” Campbell wrote in the letter dated Oct. 30. “I respectfully request a written response within 30 days of this letter addressing these concerns and detailing the corrective measures the commission intends to pursue.”

Although the commission voted to approve the permit on Oct. 22, it is not yet final, as parties have 25 days from the date the decision was signed, Oct. 28, to file for a rehearing. Attorneys for the permit protestants, the Greater Edwards Aquifer Alliance and the city of Grey Forest, currently are preparing their rehearing request.

Campbell’s letter came to light Wednesday night when her district director Joyce Yannuzzi announced it during a general meeting of the Scenic Loop-Helotes Creek Alliance in Grey Forest. The proposed development would be in the senator’s District 25, west of the intersection of Scenic Loop and Babcock roads.

Campbell joins three other state senators who also signed a letter to the commission opposing the permit, in addition to all 10 members of the state House delegation from Bexar County who signed a separate letter, bringing total bipartisan opposition to 14 legislators. See Campbell’s full letter, here: https://www.scenicloop.org/wp-content/uploads/Sen-Donna-Campbell-Opposition.pdf

Lennar wants to build 2,900 homes on 1,160 acres of Guajolote Ranch and discharge an average of 1 million gallons a day of treated sewage into the Helotes Creek watershed. That watershed directly recharges the Trinity Glen Rose Aquifer, the water supply for the immediate area, and contributes up to 15% of the total recharge of the Edwards Aquifer, principal water source for about 2.5 million people across multiple counties.

Campbell is requesting denial of the permit, but also that the commission “formally incorporate and address” the findings of a 2020 Southwest Research Institute study, commissioned under San Antonio’s Edwards Aquifer Protection Plan. That study, she wrote, “concluded unequivocally that any wastewater discharge within the Helotes Creek watershed would degrade Edwards Aquifer recharge quality. To date, this finding has not been scientifically refuted.”

She also noted that the proposed wastewater discharge site lies within habitat supporting federally protected species, citing two in particular. “Excluding these species from review contradicts Section 7 of the Endangered Species Act and the recommendations of the (TCEQ’s) Office of Public Interest Counsel,” she wrote.

Unlike the previous legislator letters, Campbell noted concern with TCEQ’s own procedures in considering the permit. Specifically, she said that changes to the administrative record following public hearings, without notice or consent, appear inconsistent with the Texas Government Code. And, the permit applicant’s removal of an originally proposed retention pond – previously essential to effluent compliance – rendered prior modeling invalid.

“Proceeding under these circumstances compromises the transparency and integrity of the permitting process,” she wrote.

Finally, Campbell noted that TCEQ staff reportedly stated that groundwater impacts are “not considered” in decisions on Texas Pollutant Discharge Elimination System (TPDES)  permits, like the one for Guajolote Ranch, and yet that contradicts the commission’s own Edwards Aquifer Protection Program, “which recognizes direct surface-to-groundwater connectivity in karst regions.”

And, she wrote, public assurances that effluent would be “safe to drink” conflict with the permit’s failure to meet Type 1 reclaimed water standards.

“Such inconsistencies erode public trust and obscure the legitimate environmental risks associated with discharge in sensitive recharge zones,” she wrote.

Campbell is requesting that the commission clarify its statements regarding effluent safety, and reconcile its “conflicting positions” on groundwater protection between its TPDES and Edwards Aquifer programs.



The Scenic Loop-Helotes Creek Alliance is a nonpartisan, nonprofit 501(c)(3) group representing the largest neighborhood by square mile recognized by the San Antonio Neighborhood & Housing Services Department, a wide corridor along Scenic Loop Road from Bandera Road to north of Babcock Road.

Scenic Loop-Helotes Creek Alliance contacts:
 
Randy Neumann, SL-HCA steering committee chair, 210-867-2826, uhit@aol.com
Steve Lee, 210-415-2402, text; slee_78023@yahoo.com

Photo: Joyce Yannuzzi, district director for State Sen. Donna Campbell, announces the senator’s letter opposing the Guajolote Ranch permit to a general meeting of the Scenic Loop-Helotes Creek Alliance.

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