Dec. 4, 2025 – Texas state Sen. Donna Campbell, R-New Braunfels, is stepping up her opposition to a wastewater permit for the proposed controversial Guajolote Ranch development of Lennar Corp. in northwest Bexar County, calling for the Texas Commission on Environmental Quality to grant a motion for rehearing.
In a Dec. 2 letter to commission Chairwoman Brooke Paup, submitted by her office along with letters from Grey Forest Mayor Paul Garro and landowner Ann Toepperwein, Campbell charges that the administrative record for the permit approved by TCEQ demonstrates “substantial and material deficiencies.” She says the matter has moved “beyond a localized dispute and into the realm of statewide public health and resource protection.”
The new correspondence follows her Oct. 30 letter to Paup that urged denial of the permit. Since then, on Nov. 24, attorneys for the Greater Edwards Aquifer Alliance and the city of Grey Forest filed the motion for rehearing that Campbell is now supporting.
If the TCEQ doesn’t respond within 55 days of Paup’s Oct. 28 signed order approving the permit – which would indicate Dec. 22 – the decision stands. At that point, opponents would have another 30 days to appeal in Travis County district court, which could trigger prolonged court proceedings.
Florida-based 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 – and up to 4 million gallons on any day. 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.
The proposed development would be in the senator’s District 25, west of the intersection of Scenic Loop and Babcock roads.
In her new letter, Campbell notes that a Southwest Research Institute study concluding that wastewater discharge into the Helotes Creek watershed would degrade the quality of water recharging the Edwards Aquifer has “not been refuted” – and that “setting aside these unchallenged findings directly undermines the technical basis for the permit and compromises the commission’s statutory duty to prevent the degradation of state waters.”
View Campbell’s full Dec. 2 letter here: https://www.scenicloop.org/wp-content/uploads/Senator-Donna-Campbell-Guajolote-Ranch-Support-Motion-for-Rehearing-.pdf
Further, she says that local officials and other members of the legislature have highlighted how “well-documented” it is that the Trinity Glen Rose and Edwards aquifers are connected, “which together serve as the primary drinking water supply for surrounding communities and millions of Texans.”
“Potential impacts to these interconnected systems elevate this matter beyond a localized dispute and into the realm of statewide public health and resource protection,” she writes.
Previously, three other state senators 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.
As she did in her previous letter, Campbell hits at inconsistencies between TCEQ’s Texas Pollutant Discharge Elimination System (TPDES) program, under which the Guajolote Ranch permit was approved, and its Edwards Aquifer Protection Program. She says that clarification is necessary to “ensure alignment, transparency and scientific coherence.”
“This is especially critical in sensitive karst regions where water pathways between the surface and groundwater are well established,” she writes. The motion for rehearing, she says, is necessary “for a complete, science-based evaluation of the unresolved issues in this matter.”
“Granting it will ensure the commission can correct procedural deficiencies, fully reassess the record and verify that the permitting decision aligns with all applicable state and federal requirements, which is essential to upholding both the law and the public interest.”
Grey Forest Mayor Garro also calls for a rehearing in his detailed letter submitted by Campbell’s office.
“The TCEQ approval of (the permit) was an enormous disappointment and seemingly contrary to your mission,” he writes, in remarks directed to the commissioners. “However, this fight is not over. Along with our residents, I assert that there have been obvious and serious shortcomings in the process.”
Like Campbell, Garro criticizes the commission’s apparent disregard of the Southwest Research Institute study, saying it seems to have ignored sound science. “The TCEQ appears to have entirely disregarded the only scientific study of the area’s hydrogeological characteristics,” he writes.
He also alleges procedural missteps in the permit process, secret settlements, and exclusion of both crucial evidence and consideration of emerging contaminants like PFAS “forever chemicals,” as well as a misplaced burden.
“TCEQ seems to put the burden of proving the safety of a (wastewater treatment facility) on those who will be affected the most (residents of Grey Forest, Helotes and San Antonio), rather than on those who will be completely unaffected (Florida-based Lennar Corp. developers),” he writes.
See Garro’s full letter, here: https://www.scenicloop.org/wp-content/uploads/Motion-for-TCEQ-Rehearing-from-Grey-Forest-Mayor-Garro.pdf
Toepperwein, 80, who lives on land abutting Guajolote Ranch that has been in her family for more than 140 years, makes an emotional appeal to the commission in her letter, noting that the “treated sewage water authorized under this permit would discharge directly into the creek on my land.”
“I am deeply saddened that TCEQ has failed to uphold its own mission statement,” she writes. “I don’t believe the decision you made follows any of your agency’s mission or philosophies.”
She originally was granted standing by TCEQ to contest the permit, and her representation was brought under the Greater Edwards Aquifer Alliance in the case.
“As a person of standing, a citizen of Texas and a human being whose family has stewarded this land for generations, I respectfully ask the commission to reconsider its decision,” she wrote. “Water is precious. Lives are precious. The responsibility to protect them rests in your hands.”
See Toepperwein’s full letter, here: https://www.scenicloop.org/wp-content/uploads/Ann-Topperweins-Letter-for-Campbell.pdf
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