AIRW 2017-7, L.P.; 600 WESTINGHOUSE INVESTMENTS, LLC; 800 WESTINGHOUSE INVESTMENTS, LLC; TEXAS COMMISSION ON ENVIRONMENTAL QUALITY; AND JONAH WATER SPECIAL UTILITY DISTRICT v. CITY OF GEORGETOWN, TEXAS
No. 15-24-00132-CV
IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
9/19/2025
ACCEPTED 15-24-00132-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/19/2025 3:50 PM CHRISTOPHER A. PRINE CLERK. FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 9/19/2025 4:31:28 PM CHRISTOPHER A. PRINE Clerk
Trial Court Cause No. D1-GN-23-001004
REPLY BRIEF OF APPELLANT JONAH WATER SPECIAL UTILITY DISTRICT
John J. Carlton
State Bar No. 03817600
Kelli A. N. Carlton
State Bar No. 15091175
Erin R. Selvera
State Bar No. 24043385
THE CARLTON LAW FIRM, P.L.L.C.
4301 Westbank Drive, Suite B-130
Austin, Texas 78746
john@carltonlawaustin.com
kelli@carltonlawaustin.com
erin@carltonlawaustin.com
Telephone: (512) 614-0901
Facsimile: (512) 900-2855
ATTORNEYS FOR JONAH WATER SPECIAL UTILITY DISTRICT
ORAL ARGUMENT REQUESTED
TABLE OF CONTENTS
TABLE OF CONTENTS .......................................................................................... ii
GLOSSARY OF ACRONYMS AND TECHNICAL TERMS ................................ vi
SUMMARY OF THE ARGUMENT ......................................................................... 1
ARGUMENT ............................................................................................................. 3
I. The District Court erred in reversing and remanding the matter to the agency. . 3
A. The District Court failed to consider the evidence in the record as whole. .... 4
B. The District Court also failed to apply the proper legal standard when considering the City‘s arguments. .......................................................................... 4
1. The City fails to identify a substantial right that has been prejudiced. ........ 5
2. The City has failed to establish how it was harmed by the Commission‘s decision to issue the permit to AIRW. ................................................................. 7
II. The City‘s misinterpretation of the requirements for permit issuance is not a basis for reversible error. ............................................................................................ 9
A. Diminution of Property Value is a valid cost factor. .....................................10
B. AIRW‘s actions constitute denial of service. ................................................11
C. The State‘s Regionalization Policy does not create a mandatory duty for TCEQ to deny the permit to AIRW. .....................................................................13
D. The State‘s Regionalization Policy does not equate to a legal right for the City to serve the AIRW development. .................................................................14
E. Lack of Consent from Jonah is a bar to the City becoming the service provider for the AIRW development. ...................................................................15
1. Consent is an independent legal requirement under Texas Water Code § 13.244(c). ..........................................................................................................16
2. It is irrelevant whether Jonah has a wastewater CCN or facilities available to serve the AIRW develоpment. ......................................................................17
CONCLUSION AND PRAYER ..............................................................................19
CERTIFICATE OF COMPLIANCE .......................................................................21
CERTIFICATE OF SERVICE .................................................................................22
INDEX OF AUTHORITIES
Cases
Bizios v. Town of Lakewood Vill., 453 S.W.3d 598 (Tex. App.—Fort Worth 2014), aff‘d, 493 S.W.3d 527 (Tex. 2016)........................................................................ 8
Cf. Nobles v. Employees Ret. Sys. of Tex., 53 S.W.3d 483, 489 (Tex. App.—Austin 2001, no pet.). ......................................................................................................... 7
Dyer v. Tex. Comm‘n on Env‘t Quality, 646 S.W.3d 498, 514 (Tex. 2022). ..........2, 4
Nueces Canyon Consolidated I.S.D. v. Central Education Agency, 917 S.W.2d 773, 777 (Tex. 1996) ............................................................................................... 6
Office of Pub. Util. Counsel v. Pub. Util. Comm‘n, 185 S.W.3d 555, 576 (Tex. App.—Austin 2006, pet. denied). ........................................................................... 5
Pub. Util. Com. v. Gulf States Utils. Co., 809 S.W.2d 201 (Tex. 1991). ................... 4
Save Our Springs All., Inc. v. Texas Comm‘n on Env‘t Quality, 713 S.W.3d 308, 320 (Tex. 2025), reh‘g denied (June 20, 2025) (quoting
Tex. Health Facilities Com. v. Charter Med.-Dallas, Inc., 665 S.W.2d 446 (Tex. 1984) ....................................................................................................................... 5
Tex. Health Facilities Comm‘n v. Charter Med.-Dall., Inc., 665 S.W.2d 446, 452 (Tex. 1984). ............................................................................................................. 4
Vandygriff v. First Sav. & Loan Asso., 617 S.W.2d 669, 672 (Tex. 1981). ................ 6
Statutes
Other Authorities
Black‘s Law Dictionary 1324 (6th Ed. 1990). ............................................................ 6
GLOSSARY OF ACRONYMS AND TECHNICAL TERMS
| Term | Meaning |
|---|---|
| AIRW | Intervenor AIR-W 2017-7, L.P., Applicant and Intervenor Defendant-Appellant |
| APA | Administrative Procedure Act, |
| Application | AIR-W 2017-7, L.P.‘s application for a new TPDES permit filed with the TCEQ on April 6, 2020 |
| AR | Administrative Record contained within the SCR |
| CCN | Certificate of Convenience and Necessity |
| City | City of Georgetown, Plaintiff-Appellee |
| Commission | Appellant Texas Commission on Environmental Quality (TCEQ) |
| ETJ | Extraterritorial Jurisdiction |
| Final Order | Final Order issued by TCEQ on November 28, 2022 |
| FOF | Finding of Fact |
| Jonah | Jonah Water Special Utility District, Intervenor Defendant-Appellant |
| Order | TCEQ‘s final order, issued November 28, 2022 |
| Permit | TPDES Permit Number WQ0015878001 |
| Regionalization Policy | The combination of |
| SOAH | State Office of Administrative Hearings |
| TAC | Texas Administrative Code |
| TCEQ | Texas Commission on Environmental Quality (“Commission“) Defendant-Appellant |
| TPDES | Texas Polluant Discharge Elimination System |
| TWC | Texas Water Code |
SUMMARY OF THE ARGUMENT
Georgetown provides no colorable argument or basis to find that the Commission committed reversible error. The City‘s skewed arguments merely signal its displeasure with the Commission‘s Order and the City‘s deep desire to be the wastewater service provider for Appellant, AIRW‘s development. Georgetown‘s brief focuses on two issues that are not dispositive regarding compliance or consistency with Texas’ Regionalization Policy.
The District Court considered the City‘s plethora of arguments challenging TCEQ‘s decision to issue the permit to AIRW, and disposed of all issues but two:
- Defendant erred by determining that the Permit complies with Texas‘s regionalization policy.
- Because Intervenor AIRW failed to seek a waiver from Plaintiff‘s city council, there is no way to know whether the city council would be willing to waive the annexation requirement. It is unreasonable to assume that City staff—who are bound by the city council—speak for the city council, which is not bound and has both the power to waive requirements and the ability to act under political considerations. This means that Defendant should not have determined both that (1) Plaintiff denied Intervenor AIRW service; and (2) connection to Plaintiff‘s system would cost Intervenor AIRW $20 million.
Now, the City urges this court to re-weigh evidence regarding these two points and the other alleged errors in the City‘s original appeal. When you strip away the issues disposed of by the District Court, the City‘s arguments are reduced to just two aspects of the TCEQ‘s regionalization analysis: denial of service and cost. It is
Furthermore, the City‘s myopic focus on the cost and denial of service aspects of regionalization are a mere distraction. Even if the City‘s regionalization arguments were substantiated, the City would remain in the very same position: without any authority to provide wastewater service to the AIRW development. Regardless of whether TCEQ committed rеversible error, an act the City has failed to prove, the Court cannot grant the true relief the City seeks (to be the service
ARGUMENT
I. The District Court erred in reversing and remanding the matter to the agency.
The District Court issued its Final Judgment reversing and remanding TCEQ‘s Order for further proceedings, asserting the following reasons:
- Defendant erred by determining that the Permit complies with Texas’ regionalization policy.
- Because Intervenor AIRW failed to seek a waiver from Plaintiff‘s city council, there is no way to know whether the city council would be willing to waive the annexation requirement. It is unreasonable to assume that City staff – who are bound by the city council-speak for the city council, which is not bound and has both the power tо waive requirements and the ability to act under political considerations. This means that Defendant should not have determined both that (1) Plaintiff‘s denied Intervenor AIRW service; and (2) connection to Plaintiff‘s system would cost Intervenor AIRW $20 million. Final Judgment.
A. The District Court failed to consider the evidence in the record as whole.
Under the substantial evidence standard, the Appellate Court‘s inquiry is whether the Commission‘s decision is reasonably supported by substantial evidence in view of the reliable and probative evidence in the record as a whole.
B. Thе District Court also failed to apply the proper legal standard when considering the City‘s arguments.
To reverse and remand the matter to the agency, the District Court must first have found that the City‘s substantial rights were prejudiced. Dyer v. Tex. Comm‘n on Env‘t Quality, 646 S.W.3d 498, 514 (Tex. 2022). (“Not only must the agency‘s challenged findings, inferences, conclusions or decisions be faulty as a matter of law; they must also prejudice the substantial rights of the appellant.” (internal
1. The City fails to identify a substantial right that has been prejudiced.
The Administrative Procedures Act (“APA“)
Substantial rights are not defined in the APA. A “right” is generally defined as a power, privilege, or immunity guaranteed under the Constitution, statutes, decisions, laws, or are claimed as a result of long usage. Black‘s Law Dictionary 1324 (6th Ed. 1990). The City, a home rule municipality, has authority of local self government.
Unlike Jonah, which has a statutory right to protect its district boundaries and to grant or deny consent to entities seeking to serve within the District, the City has
2. The City has failed to establish how it was harmed by the Commission‘s decision to issue the permit to AIRW.
The City‘s brief is completely devoid of any discussion of harm or injury that the City has sustained that would warrant remand and reversal. Cf. Nobles v. Employees Ret. Sys. of Tex., 53 S.W.3d 483, 489 (Tex. App.—Austin 2001, no pet.). (“An appellate court reviews an agency decision for reversible error; harmless error does not merit reversal. A showing of injury to the claimant is necessary before reversal is the apрropriate remedy.“)
The record confirms that AIRW‘s proposed wastewater treatment plant will not be located within the City limits where the City enjoys broad authority. 1 AR 66 at 10 FOF 34. Instead, the wastewater plant will be located in the City‘s ETJ,
Even if the Commission were to address each of the City‘s points of error on remand (the City‘s denial of service, costs to the developer, the alleged application deficiencies, and water quality concerns), the City would be in the same position as it is today – without authority to provide service to the AIRW development and having suffered no harm or prejudice to its substantial rights. Because the City has
II. The City‘s misinterpretation of the requirements for permit issuance is not a basis for reversible error.
The first five sections of the City‘s appellate argument (A-E) focus on different aspects of Texas’ Regionalization Policy and how the Commission applied the policy to AIRW‘s application. The City misinterprets the policy in two key ways. First, the City would have the court believe that Texas’ Regionalization Policy creates a mandatory duty for the agency to deny a permit in certain circumstances. Second, the City’ perceives the Policy to create a right for the City to serve the area if it meets certain criteria. Neither of these premisеs are correct. Additionally, under Texas’ Regionalization Policy and its associated guidance, diminution of property values is a valid cost factor. Finally, AIRW‘s actions were sufficient to constitute denial of service.
The remaining arguments under Sections F-K either skirt a key jurisdictional issue or ask the court to re-weigh evidence. Section F merely skims the concept of consent. In Sections G-K, the City asks the Court to re-weigh evidence regarding the Commission‘s water quality, antidegradation, nuisance odors, human health, and
A. Diminution of Property Value is a valid cost factor.
Unhappy with the Commission‘s decision, the City argues that the Commission‘s exercise of its legislatively granted discretion was unreasonable or abusеd. The City takes the position that it was unreasonable for the Commission to consider diminution of value as justification for issuance of the permit instead of denial. Georgetown Br. at 12. The City also acknowledges “the statute does not limit the Commission‘s discretion to consider the cost impacts of the City‘s annexation requirements and development regulations,” but posits that guidance and broader statutory requirement do. Georgetown Br. at 29. The City is wrong. TCEQ guidance specifically requires the applicant to analyze feasibility of regionalization and allows exceptions upon the:
- ratio of the costs of regionalization compared to the projected value of the development at buildout;
- affordability of the rates; and
financial, managerial, and technical capabilities of the existing system.
2 AR 99-AIRW-EX.29 at AIRW000402. Permit applicants qualify for this exception, even if they meet only one of these factors. Id. AIRW‘s calculation of the diminished value of the property at full buildout is a specific factor in the exception analysis, and thus, is a proper cost factor. The Commission‘s guidance reflects the agency‘s broad discretion tо consider cost and other relevant factors, a point the City repeatedly concedes, but then disputes. Georgetown Br. at 10, 26, 29. Here, the guidance is clear: projected value of the development is a cost factor. 2 AR 99-AIRW-EX.29 at AIRW000402. Therefore, the Commission‘s findings that, “Because of the higher property tax rate inside the City than outside it in the unincorporated area and the City‘s condition of annexation to connect to its system, connecting carries with it an approximately $20 million cost due to diminution of property value” and “Costs weigh in favоr of granting AIRW‘s application” are consistent with Texas’ Regionalization Policy, the Commission‘s rules, and its guidance. 1 AR 66 at 11 FOF 46.
B. AIRW‘s actions constitute denial of service.
Georgetown and the District Court‘s overly restrictive view of the Commission‘s authority is incongruent with the Legislature‘s grant of broad discretion regarding implementation of Texas’ Regionalization Policy. Neither the
I understand that you prefer to not connect to the City‘s public wastewater system. Both in our meeting and in Sofia‘s e-mail communication with you, we have been clear that should you desire or
need to connect to the City‘s wastewater system you would have annex [submit a petition for voluntary annexation per City‘s UDC]; Sofia provided you with the pertinent UDC provisions that speak to this. Also, Sofia confirmed that we do not support a delayed annexation approach. Because you do not want to annex, you can develop in the ETJ with a private water treatment facility. Id.
Texas’ Regionalization Policy does not require a developer to agree to an annexation to get service from a nearby system, nor does it require a developer to receive a formal denial of service. Based on the Commission‘s guidance and the totality of the correspondence, the Commission properly and reasonably exercised its discretion, finding “[t]he City denied AIRW‘s request for service unless AIRW agreed to annexation and land use restrictions.” 1 AR 66 at 11 FOF 42. “Under the APA, a court reviewing an agency‘s decision in a contested case ‘may not substitute its judgment for the judgment of the state agency on the weight of the evidence on questions committed to agency discretion.‘” Save Our Springs All., Inc. v. Texas Comm‘n on Env‘t Quality, 713 S.W.3d 308, 320 (Tex. 2025), reh‘g denied (June 20, 2025) (quoting
C. The State‘s Regionalization Policy does not create a mandatory duty for TCEQ to deny the permit to AIRW.
D. The State’s Regionalization Policy does not equate to a legal right for the City to serve the AIRW development.
The City argues that its system was available and criticizes AIRW’s position regarding this availability. Georgetown Br at 14. Physical availability does not equate to legal availability or the legal authority to serve. Absent Jonah’s Consent, the City’s system is not available because the City is not legally able to provide wastewater service to the AIRW development under
E. Lack of Consent from Jonah is a bar to the City becoming the service provider for the AIRW development.
The City is displeased with the result of the Commission’s exercise of its broad discretion in application of the state’s regionalization policy, state law, and commission rules. The sobering fact is that this means the City will not be the wastewater provider for the AIRW development. Even if the Commission had found that the City had not denied service, had improperly chosen to ignore the costs associated with diminution of property value, and had required the City to address certain aspects of the application differently, the Commission could still have issued
1. Consent is an independent legal requirement under Texas Water Code § 13.244(c) .
The City buries within its forty-plus page brief, a less than one page and nearly nonexistent argument regarding consent. The City simply did not seek or receive Jonah’s consent to provide wastewater service within Jonah’s District boundaries. The City tries to skirt the issue by arguing that consent is not a procedural requirement under the Regionalization analysis. Georgetown’s Br. at 29-30. The City is correct that consent is not part of the analysis under
Each applicant for a certificate or for an amendment shall file with the utility commission evidence required by the utility commission to show that the applicant has received the required consent, franchise, or permit of the proper municipality or other public authority.
Tex. Water Code § 13.244(c) .
The City has not sought a CCN to serve the AIRW development and did not seek Jonah’s consent to provide service in this area. 1 AR 66 at 11 FOF 52.
2. It is irrelevant whether Jonah has a wastewater CCN or facilities available to serve the AIRW development.
The City is so fоcused on its regionalization argument that it loses sight of the broader statutory limitations that affect service to the AIRW development. The City attempts to brush aside the issue of consent, arguing that Jonah does not provide wastewater services and does not have a wastewater CCN. Georgetown’s Br. at 29-30. It matters not whether Jonah has a wastewater CCN, nor whether Jonah has facilities available to provide wastewater services. The only relevant inquiry is whether Jonah has granted consent to allow the City to provide wastewater services within its District boundаries pursuant to
3. The location of the AIRW development imposes additional requirements that include seeking Jonah’s consent if the City desires to be the service provider.
The City falsely claims that the location of the Development does not affect the City’s ability to serve the AIRW development with wastewater services. Georgetown’s Br. at 29-30. Nothing could be further from the truth. As explained above, the City’s authority is limited within the ETJ. If the AIRW development were within the City’s corрorate limits, the City could unquestionably provide service without seeking a CCN. Municipalities have exclusive original jurisdiction to provide water and wastewater service within their corporate boundaries without a CCN.
CONCLUSION AND PRAYER
Evidence in the record demonstrates that the Commission acted reasonably and within its authority and discretion in granting AIRW the TPDES Permit. Substantial evidence demonstrates that the Permit complies with all applicable statutory and regulatory requirements and with Texas’ Regionalization Policy. None of the City’s substantial rights were violated, and thus, the District Court erred in reversing the Commission’s order. For these reasons, Jonah respectfully prays that the Court reverse the District Court’s judgment and render judgment affirming the Commission’s Order in all respects. Jonah further prays the Court grant Jonah all further relief to which it may be entitled.
Respectfully submitted,
Erin R. Selvera
John J. Carlton
State Bar No. 03817600
john@carltonlawaustin.com
Kelli A. N. Carlton
State Bar No. 15091175
kelli@carltonlawaustin.com
Erin R. Selvera
State Bar No. 24043385
erin@carltonlawaustin.com
THE CARLTON LAW FIRM, P.L.L.C.
4301 Westbank Drive, Suite B-130
Austin, Texas 78746
Telephone: (512) 614-0901
Facsimile: (512) 900-2855
ATTORNEYS FOR JONAH WATER SPECIAL UTILITY DISTRICT
CERTIFICATE OF COMPLIANCE
I certify that the Brief of Appellant, Jonah Water Special Utility District contains 4,415 words and therefore complies with the word limit found in
_________________________
Erin R. Selvera
CERTIFICATE OF SERVICE
I certify that the Brief of Appellant, Jonah Water Special Utility District was electronically filed with the Clerk of the Court using the electronic case filing system of the Court, and that a true and correct copy was served upon counsel for each party of record, listed below, by electronic service or email on September 19, 2025.
Defendant-Appellant
Texas Commission on Environmental Quality:
Evan Greene
Assistant Solicitor General
Evan.Greene@oag.texas.gov
Sara J. Ferris
Assistant Attorney General
Sara.Ferris@oag.texas.gov
OFFICE OF THE ATTORNEY GENERAL
Environmental Protection Division
P.O. Box 12548, MC-066
Austin, Texas 78711-2548
Telephone: (512) 463-2012
Fax: (512) 320-0911
Plaintiff-Appellee
City of Georgetown, Texas:
William A. Faulk, III
cfaulk@spencerfane.com
Carlota Hopinks-Baul
chbaul@spencerfane.com
Maris M. Chambers
mchambers@spencerfane.com
SPENCER FANE, LLP
816 Congress Avenue, Suite 1200
Austin, Texas 78701
Telephone: 512-840-4550
Fax: 512-840-4551
Patricia Erlinger Carls
tcarls@tcarlslaw.com
LAW OFFICES OF PATRICIA ERLINGER CARLS
Austin, Texas 78703-1443
Intervenor Defendants-Appellants:
AIRW 2017-7, L.P.; 600 Westinghouse Investments, LLC; and 800 Westinghouse Investments, LLC
Andrew Davis
Andrew@lkcfirm.com
William T. Thompson
will@lkcfirm.com
Todd Disher
todd@lkcfirm.com
Michael C. Cotton
michael@lkcfirm.com
LEHOTSKY KELLER COHN, LLP
408 W. 11th Street, 5th Floor
Austin, TX 78701
Telephone: 512-693-8350
Helen S. Gilbert
hgilbert@bartonbensonjones.com
BARTON BENSON JONES, PLLC
7000 North MoPac Expressway, Suite 200
Austin, Texas 78731
Edmond McCarthy
Ed@ermlawfirm.com
MCCARTHY & MCCARTHY, LLP
122 Colorado St. Suite 2399
Austin, TX 78701
_________________________
Erin R. Selvera
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Katy Hennings on behalf of John Joseph Carlton
Bar No. 3817600
katy@carltonlawaustin.com
Envelope ID: 105857011
Filing Code Description: Brief Requesting Oral Argument
Filing Description: Brief Requesting Oral Argument
Status as of 9/19/2025 4:37 PM CST
Associated Case Party: City of Georgetown
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| Patricia Carls | 3813425 | tcarls@tcarlslaw.com | 9/19/2025 4:31:28 PM | SENT |
| Carlota Hopinks-Baul | 24094039 | chbaul@spencerfane.com | 9/19/2025 4:31:28 PM | SENT |
| Skye Masson | Skye.Masson@georgetowntexas.gov | 9/19/2025 4:31:28 PM | SENT | |
| Kelsey Parker | kparker@spencerfane.com | 9/19/2025 4:31:28 PM | SENT | |
| Maris Chambers | MChambers@spencerfane.com | 9/19/2025 4:31:28 PM | SENT |
Case Contacts
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| William Thompson | 24088531 | will@lkcfirm.com | 9/19/2025 4:31:28 PM | SENT |
| Edmond McCarthy | 13367200 | ed@ermlawfirm.com | 9/19/2025 4:31:28 PM | SENT |
| William Faulk | 24075674 | cfaulk@spencerfane.com | 9/19/2025 4:31:28 PM | SENT |
| John Carlton | 3817600 | john@carltonlawaustin.com | 9/19/2025 4:31:28 PM | SENT |
| Michael Parsons | 24079109 | michael@carltonlawaustin.com | 9/19/2025 4:31:28 PM | SENT |
| Helen Gilbert | 786263 | hgilbert@bartonbensonjones.com | 9/19/2025 4:31:28 PM | SENT |
| Colton Halter | colton.halter@oag.texas.gov | 9/19/2025 4:31:28 PM | SENT | |
| Todd Disher | todd@lkcfirm.com | 9/19/2025 4:31:28 PM | SENT | |
| Kelli Carlton | kelli@carltonlawfirm.com | 9/19/2025 4:31:28 PM | ERROR | |
| Erin Selvera | erin@carltonlawfirm.com | 9/19/2025 4:31:28 PM | ERROR |
Associated Case Party: Texas Commission on Environmental Quality
Name BarNumber Email TimestampSubmitted Status
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Katy Hennings on behalf of John Joseph Carlton
Bar No. 3817600
katy@carltonlawaustin.com
Envelope ID: 105857011
Filing Code Description: Brief Requesting Oral Argument
Filing Description: Brief Requesting Oral Argument
Status as of 9/19/2025 4:37 PM CST
Associated Case Party: Texas Commission on Environmental Quality
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| Kellie E. Billings-Ray | Kellie.Billings-Ray@oag.texas.gov | 9/19/2025 4:31:28 PM | SENT | |
| Erin K. Snody | Erin.Snody@oag.texas.gov | 9/19/2025 4:31:28 PM | ERROR | |
| Sara Ferris | sara.ferris@oag.texas.gov | 9/19/2025 4:31:28 PM | SENT | |
| Jennifer Jamison | jennifer.jamison@tceq.texas.gov | 9/19/2025 4:31:28 PM | ERROR | |
| Bobby Salehi | bobby.salehi@tceq.texas.gov | 9/19/2025 4:31:28 PM | ERROR | |
| Evan Greene | evan.greene@oag.texas.gov | 9/19/2025 4:31:28 PM | SENT |
Associated Case Party: AIRW 2017-7, LP
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| Andrew Davis | andrew@lkcfirm.com | 9/19/2025 4:31:28 PM | SENT |
Associated Case Party: AIRW 2017-7, L.P.
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| Yahaira De Lara | ydelara@bartonbensonjones.com | 9/19/2025 4:31:28 PM | SENT | |
| Michael Cotton | michael@lkcfirm.com | 9/19/2025 4:31:28 PM | ERROR |
Associated Case Party: Jonah Water Special Utility District
| Name | BarNumber | TimestampSubmitted | Status | |
|---|---|---|---|---|
| John Carlton | john@carltonlawfirm.com | 9/19/2025 4:31:28 PM | ERROR |
