TPW Commission

Work Session, November 6, 2024

Transcript

TPW Commission Meetings

TEXAS PARKS AND WILDLIFE COMMISSION

November 6, 2024

TEXAS PARKS AND WILDLIFE DEPARTMENT

SOLOMON P. ORTIZ INTERNATIONAL CENTER, NUECES ROOM

400 HARBOR DRIVE

CORPUS CHRISTI, TEXAS 78401

WORK SESSION

CHAIRMAN JEFFERY D. HILDEBRAND: Good morning. Everybody hear me?

All right. Welcome to Corpus Christi, Texas. Before I start, really, we want to thank the City of Corpus Christi and the Port of Corpus Christi on being great hosts for us. This is an interesting and unique venue, and so we’re excited to be here.

So, we just thank you for all the hospitality.

Good morning, everyone. Before we begin, I’ll take role.

I, Chairman Hildebrand, am present. Vice Chair Bell?

VICE-CHAIRMAN OLIVER BELL: Present.

CHAIRMAN HILDEBRAND: Commissioner Abell?

COMMISSIONER JAMES ABELL: Present.

CHAIRMAN HILDEBRAND: Commissioner Doggett?

COMMISSIONER LESLIE DOGGETT: Present.

CHAIRMAN HILDEBRAND: Commissioner Galo?

COMMISSIONER ANNA GALO: Present.

CHAIRMAN HILDEBRAND: Commissioner Scott?

COMMISSIONER DICK SCOTT: Present.

CHAIRMAN HILDEBRAND: Okay. All right. We do have a quorum, correct? Yes. All right, thank you.

This meeting is called to order November 6, 2024, at 9:03 a.m.

Before proceeding with any business, I believe Dr. Yoskowitz has a statement to make.

DR. DAVID YOSKOWTIZ: Public notice of this meeting containing all items on the proposed agendas has been filed in the Office of the Secretary of State as required by Chapter 551, Government Code, referred to as the Open Meetings Act. I would like for this fact to be noted in the official record of this meeting.

CHAIRMAN HILDEBRAND: Right. Thanks, David. Commissioners, as a reminder, please turn on your microphones and announce your name before you speak.

The first order of business is the approval of minutes from the previous work session held August 21, 2024, which has already been distributed.  Is there a motion for approval?

COMMISSIONER SCOTT: So, moved. Commissioner Scott.

VICE-CHAIRMAN BELL: Commissioner Bell, second.

CHAIRMAN HILDEBRAND: All in favor please say, “Aye”.

[ CHORUS OF AYES ]

Any opposed? Hearing none, motion carries. Thank you.

Next order of business is the approval of minutes from the previous annual public hearing held August 21, 2024, which has already been distributed.

Is there a motion for approval?

COMMISSIONER ABELL: Abell, so moved.

CHAIRMAN HILDEBRAND: Is there a second?

COMMISSIONER SCOTT: Second. Commissioner Scott.

CHAIRMAN HILDEBRAND: All in favor, please say aye.

(CHORUS OF AYES)

Any opposed? Hearing none, motion carries. Thank you.

Work Session Item Number 1: Update on the Texas Parks and Wildlife Department’s Progress in Implementing the Texas Parks and Wildlife Department Land and Water Resources, Conservation and Recreation Plan.

There’s a lot of internal affairs updates, staff, I won’t go through it all. Dr. Yoskowitz, please make your presentation, and we’ll hit all these issues.

DR. YOSKOWITZ: Thank you, Chairman. Chairman, good morning, Commissioners. For the record, my name is David Yoskowitz, Executive Director of Texas Parks and Wildlife Department.

I’d like to provide you an update germane to the Land and Water related plan and functions inside of the Department.

But before I do that, I also want to give my welcome to the Commission here to Corpus Christi, the Coastal Bend. It’s been since November of 2018 that the Commission has last been on a road for a commission meeting. Commissioner Scott, you well know that. So, it’s great to be here. I also want to share my appreciation for the staff of the department, moving this machine even a few hours from Austin takes a lot of effort. So I appreciate all the staff that have been working on that. Also, our great partners at the Port.

They have been absolutely excellent in the transition of moving the commission meeting here. So, thank you to the Port of Corpus Christi. I also want to let people know in the audience and the commissioners that we have our 80‑foot Captain Murchison offshore patrol vessel that is tied up outside. And so, when you get a chance to be able to go by and take a look at it, we also will have one of our helicopters which is on route now that will be nearby to be able to look at as well.

And one last thing before I begin, Chairman, we have Professor Ashley Tanner’s Wildlife Techniques class from Texas A&M-Kingsville. Some of those students are here today in the audience and will be observing the commission meeting and process. So welcome to those members. Could you all just raise your hands? Thank you very much for being here today.

So as is tradition, I will start with the Internal Affairs Staff Update. Internal Affairs staff frequently attend and participate in meetings with other TPWD law enforcement officers. In late September, Assistant Commander Jarret Barker and Captain Joel Parker attended the annual State Park’s law enforcement senior leadership meeting where they provided a brief internal affairs update and discussed officer‑involved shooting procedures. Opportunities such as this fosters internal relationships and communication amongst leadership and staff.

In addition, Internal Affairs submitted their FY 2024 Internal Affairs Annual Report to the Texas Parks and Wildlife Commission for their review. The annual report includes a summary of FY 2024 activity cases, activity information, internal affairs initiatives for ’24 and ’25, case numbers and statistical data compiled for the annual report was collected from Internal Affairs’ IAPro Report Management System and the Law Enforcement Bear Stearns Report Management System, and you have that as a handout.

Next, I would like to introduce some of our new staff members, some important staff members, to the department. Since our last commission meeting, we have had some additional staff join us.

The first I’d like to introduce you to is Ms. Jada Louhela.

After an extensive search and interview process that evaluated a deep pool of candidates, in early September, Jada joined the TPWD team as our new Human Resources Division Director.

She brings over 25 years of experience with her, including stints as the HR Representative at the University of North Texas, Coordinator of Human Resources at the Department of Agriculture, and most recently the HR director at the Texas Historical Commission since 2015. Ms. Louhela came highly recommended by her supervisors and peers. She is someone who proactively builds trusting and professional relationships.

In addition, Ms. Louhela’s experience covers a broad spectrum of human resource roles and responsibilities which has allowed her to acclimate into her new role at TPWD quickly. Please welcome Jada Louhela.

[ APPLAUSE ]

Next, Mr. Zach Spector was chosen to fulfill TPWD’s Chief of Land and Conservation Initiatives position.

In this role, Mr. Spector reports directly to me and provides leadership capacity and engagement on a needed basis for the entire agency around conservation initiatives. Within that purview, Zach will provide programmatic oversight and direction to the Infrastructure Division’s Land Conservation Program, including land acquisitions and strategic property and conservation initiatives.

He will also be interacting with the Commission and providing updates on initiatives from time to time. Many of you already know Zach, as he comes to us from a prior role with the Texas Parks and Wildlife Foundation as the Director of Conservation.

Prior to that, he worked in various capacities within the Western Rivers Conservancy performing government affairs roles, project operations management, and a robust suite of complex conservation and real estate projects and transactions. Welcome, Zach.

[ APPLAUSE ]

And finally, as we prepare for the upcoming legislative session that will officially kick off with bill filing on Monday, November 11, in early October, Ms. Julie Frank joined the Department as Senior Advisor for Governmental Affairs.

Prior to joining us, she was part of the executive leadership team at both the Department of Family and Protective Services and in the Office of Governor under Greg Abbott. Ms. Frank, who most recently was Governor Abbott’s Director of Legislative Affairs initially was the policy liaison assigned to the Department back in 2018. So, she is very familiar with our agency’s uniqueness and our needs and before that she spent over 20 years working in the Texas Legislature.

We’re excited to have Ms. Frank as part of the TPWD Government Relations team. Is Julie in the room?

MR. DAVID EICHLER: No, she is sick.

DR. YOSKOWITZ: She couldn’t make the trip, but I wanted to introduce her to you. Thank you for joining us, Julie.

Next I’d like to share with you some staff recognitions. The Department has great staff working across the agency across many different issues. And at a recent Association of Fish and Wildlife Agencies (AFWA) Conference in Madison, Wisconsin, Ms. Michelle Haggerty of the Wildlife Division accepted AFWA’s Stephen Kellert Award on behalf of the Texas Master Naturalist Program.

Stephen Kellert explored the links between people and nature. This award recognizes the importance of connecting all the types of backgrounds to the natural world to enhance public’s appreciation for conservation and nature‑based health and well-being.

The Texas Master Naturalist Program recently celebrated its 25th anniversary, as you know, providing education, outreach and service to communities throughout Texas. The program is the first naturalist program of its kind in the nation to be implemented on a statewide scale, and it has served as a role model for other states and other countries. The program has an average of 6,000 volunteers per year in 49 chapters around the state serving 213 counties. So, congratulations to Michelle and the Master Naturalist Program. Thank you very much.

[ APPLAUSE ]

Next, we would like to recognize Mr. Shawn Gray. During the 30th Biennial Pronghorn Workshop which was held in Redmond, Oregon, Mr. Shawn Gray, the TPWD’s Mule, Deer and Pronghorn Leader, was presented a Special Recognition Award.

The workshop focused on featuring leading pronghorn managers and researchers who shared results, management strategies and emerging issues around the fastest land mammal in the Western Hemisphere.

Mr. Gray was recognized for his leadership focusing on a team-building approach, being tenacious in coordinating research, funding, and on the ground conservation efforts on private land.

Congratulations, Shawn, who is here and in a tie.

[ APPLAUSE ]

I had not seen Shawn in a tie before. Congratulations for that, Shawn.

Next, we’d like to recognize an event that took place just a short time ago. The Kiowa Tribe, Comanche Nation, Cheyenne, and Arapaho Tribes, in partnership with the Department and Texas Tech University, hosted an event to celebrate Native cultures and to mark the 150th anniversary of the Battle of Palo Duro Canyon which took place in 1874. The two‑day event noted the historical legacy of the battle and celebrated the tribes’ vibrant cultures.

The commemorative event at the Palo Duro Canyon State Park included several traditional dances, such as the Victory Dance, Gourd Dance, and Round Dance. Educational and craft booths near the Mack Dick Pavilion showcased the information about the histories and cultures of the Southern Plains Tribes. The event was the first time all the tribes were together again in the canyon since that day in September of 1874.

TPWD has a long history of wildlife and fishery stocking efforts throughout Texas to promote healthy and sustainable populations.

The utilization of stocking, combined with traditional management practices, has proven to be a powerful combination in managing Texas’ natural resources.

In accordance with the Texas Administrative Code, Title 31 Part 2, Chapter 52, Section 52.105, the TPWD Executive Director hereby submits the Agency’s Annual Stocking Report for Fiscal Year 2024 at the TPWD Commission meeting, and you have that handout.

We have made great strides in accomplishing our Land and Water Conservation and Recreation Plan and action items. And I want to highlight a few of those here this morning. For instance, Action Item 1.5: Design, plan, and implement 25 aquatic habitat restoration or enhancement projects annually in Texas creeks, rivers and lakes.

I’d like to highlight the large-scale aquatic habitat enhancement at Bois d’Arc lake, which is located northeast of Dallas-Fort Worth metroplex in Fannin County. This 26-mile impoundment of its namesake creek is the first major reservoir constructed in Texas for over 30 years. In 2016, the North Texas Municipal Water District proactively engaged the Department fishery biologist, wildlife biologist and game wardens to identified shared goals and strategies.

Outcomes achieved over the past eight years include large-scale fish habitat enhancements, including preservation of stands of timber, and construction of over 40 large habitat reefs, which you can see here in the upper left‑hand corner consisting of trees and boulders, and installation of gravel fish-spawning beds and fish attractants. TPWD is incredibly appreciative of the collaborative partnership formed with the North Texas Municipal Water District to develop this lake into a world‑class fishery, potentially competing against some of our most famous lakes in the state.

Next for Land and Water Action Item 1.6 and 1.10, referring to the management of aquatic invasive or nuisance vegetation, the Department and its partners treated nearly 9,000 acres of aquatic vegetation in Fiscal Year 2024. The previous year’s drought and cold winter temperatures and frequent spring rains/ inflows led to reduction in overall vegetation across Texas, which is a good thing, and it contributed to lower-than-anticipated need for the management of those invasive species.

Water hyacinth increased statewide from germination of seed beds and outperformed giant salvinia expanding the near three‑fold increase from previous years.

The Department released approximately 83,000 adult, giant salvinia weevils to help with the control of giant salvinia.

We grow these out in our East Texas Fish Hatchery below dam at Sam Rayburn Lake. Early detection and rapid response efforts in conjunction with timely herbicide treatments resulted in the extrication of giant salvinia from three of our East Texas reservoirs.

And next, the Land Water Item that I would like to close with is Item 8.1 and 8.2 where we are developing a cultural resource inventory strategy for Texas State Parks.

State Parks’ Cultural Resources Program has developed a strategy to prioritize locations for which to conduct inventories and published reports. The strategy applies to existing parks where cultural and archaeological significance is known, as well as new park acquisitions. Priorities are based on the division’s need for development of opening new parks. Cultural inventories are underway at parks not yet open to the public, including Albert and Bessie Kronkosky State Natural Area, Powderhorn State Park, and Palo Pinto Mountain State Park. Field work is near completion at the Albert and Bessie Kronkosky State Park Natural Area and we’re in several advanced stages at Powderhorn and Palo Pinto Mountains.

Rule Review.

I want to discuss the last group of chapters to be reviewed by TPWD under the ongoing process to review all of our Texas Administrative Code, Title 31, Part 2. Consistent with Government Code, Section 2001.039, TPWD reviews its rules on a four‑year cycle to determine whether the reason for initially adopting a rule continues to exist and has been four years since the last review.

To spread out the workload, the Department reviews its rules in three batches, and the Department has already reviewed most of the chapters. And the final set to be reviewed is Chapter 56, Agency Decision to Refuse License or Permit Issuance or Renewal and Agency Decision to Suspend or Revoke Affected License or Permit. Chapter 57: Fisheries. Chapter 58: Oysters, Shrimp and Finfish. And Chapter 65: Wildlife.

The purpose of mentioning this rule review is to notify the Commission that this is occurring. This notice also serves to create a public record of the agency’s compliance with this law, and the Department will publish a notice of its intent to review the rules in the Texas Register.

If the review finds that changes to certain rules are needed or that the need for the rule no longer exists and the rule should be repealed, the Department staff will bring that appropriate rule-making proposal to the Commission through the normal process.

In those cases where the department staff determined that the reviewed rules should remained unchanged, TPWD staff will not propose changes to the Commission but will seek readoption of the existing rules through the normal process.

Next I’d like to close out by recognizing an important individual to the Department, an important position to the Department, and that is our new Colonel and Director of Law Enforcement, Colonel Ron VanderRoest.

[ APPLAUSE ]

Don’t get up yet, Ron.

After an extensive interview process that evaluated a competitive pool of candidates, Ron VanderRoest has been selected as our new Law Enforcement Colonel and Division Director effective November 1.

Following bachelor’s and master’s degrees from Tarleton State University and a stint as a county extension agent with Texas AgriLife, Colonel VanderRoest graduated from the Texas Game Warden Academy in 2000 and received his first game warden assignment in Denton County.

He served in a leadership role in various field offices, including Captain in College Station and Major in Lubbock, where he also served as adjunct faculty at Texas Tech University instructing students in conservation law and leadership.

During his tenure, Colonel VanderRoest played a lead role in developing the Field Officer Training Program and the Captain Mentor Training Program, among other accomplishments. He moved to Austin headquarters where he was promoted to Lieutenant Colonel in 2019 and has been serving in that interim Colonel role since September 1st.

Throughout his almost 25 years of service with the Department and Law Enforcement Division, Colonel VanderRoest has demonstrated trustworthy leadership, attention to operational details while seeing the bigger picture, and being an effective communicator.

He has earned the trust and respect of his colleagues both inside the Department and with external partners and stakeholders across the board, and he is also a graduate of the FBI National Academy.

We look forward to Colonel VanderRoest fulfilling his new role as part of the agency’s senior leadership team and representing talented and dedicated team of TPWD law enforcement professionals.

Chairman, would you join me down here in the pinning of Colonel Ron VanderRoest?

CHAIRMAN HILDEBRAND: Sure.

[ APPLAUSE ]

DR. YOSKOWITZ: Chairman, that concludes my presentation.

CHAIRMAN HILDEBRAND: Okay. Any questions for Dr. Yoskowitz?

If not, congratulations to all the new hires and all that have been promoted. Specifically, Colonel, I think you’re going to be a great leader and role model for the rest of our officers. I just couldn’t be prouder of you and the Department. So, thank you and congratulations.

[ APPLAUSE ]

All right. Work Session Item Number 2, Financial Overview.

Mr. Reggie Pegues, please make your presentation.

MR. REGGIE PEGUES: Good morning, Mr. Chairman, Vice‑Chairman, Commissioners. For the record, my name is Reggie Pegues, Chief Financial Officer.

This morning, I’ll be presenting the financial overview covering the following items: FY 24 Revenue Summaries, Hunting/Fishing License Revenue, State Parks Revenue, Boat-Related Revenues, and a summary of the FY26‑27 Legislative Appropriations Request (LAR).

Before I begin, I’d like to… Before I go into specific items, I’d like to say… you may recall there was a huge spike across all three revenue sources during the pandemic period with FY21 being a record year across all lines. Since that time, there has been a leveling off; but, even with these amounts, we’re still near record levels.

I’ll begin with the revenue summaries.

This first line is a five‑year comparison of License Revenue.

License Year ’24 finished up strong at $110 million.

This is only a 5 percent drop from License Year ’21 and less than a 1 percent drop from License Year ’23.

This next slide is a two‑year comparison by license type. As mentioned, there was an overall drop of less than 1 percent from LY ‘23 to LY ‘24 with no significant variances by dollar amount..

There was a slight uptick in hunting revenues offset by slight declines across the other areas.

Next up is State Parks Revenue.

As with License Revenue, you’ll see a leveling off since the record year of ’21 to settle at $61.7 million for FY ‘24. This is only a 7.5 percent drop from record year FY ‘21 and a 1.5 percent drop from FY ‘23.

This next slide is the two‑year comparison by fee type. As mentioned, there was an overall drop of less than 1.5 percent from FY ‘23 to ’24 with no significant variances by dollar amount. Total visitation was also down by a similar percentage at 1.8 percent to finish at roughly $9 million.

Moving onto Boat Revenues.

The five‑year trend reflects a 16 percent drop from record year FY ‘21 and a 9 percent drop from License Year FY ’23 to settle at $21.6 million for FY ‘24. This is somewhat steeper than the other revenues but this is a more of a result of the two‑year registration cycle than any other factor.

And this next slide is a two‑year comparison by type showing the slight drop across all lines.

Next, I’ll be providing a summary of some of our Legislative Appropriations Request. Our Legislative Appropriations Request is our funding request for the ’26‑’27 biennium.

Our LAR was submitted in September followed up by a Joint Budget Hearing with legislative staff in October. One of the key elements framing the development of this LAR has been our ongoing concerns with Game, Fish and Water Safety, or General Fund 9 balances.

Evaluations indicate that existing funding mechanisms may be inadequate to effectively support efforts over the long‑term.

As such, many of our additional needs are requesting General Revenue appropriations in lieu of General Revenue Dedicated amounts.

Next, I’ll go over the actual items in the LAR. In terms of the actual request, it consists of two main components: the Baseline Request and Exceptional Items. The baseline limits are the amounts to maintain agency operations at the ’24‑’25 level less items deemed one time in nature. Some of these items are non-law enforcement vehicles were considered one‑time and removed from the base; $21 million in local grant funding was removed; and $600,000 for a coastal vessel were removed and considered as one‑time items.

This calculation also only applies to General Revenue and General Revenue Dedicated sources such as Fund 9, the Game, Fish and Water Safety Account and fund 64, the State Parks Account.

This does not apply to federal funds or other funds such as appropriated receipts. This figure is calculated by the Legislative Budget Board and the Office of the Governor. Items in excess of this amount are classified as Exceptional Items and submitted as a separate part of the request.

In terms of the actual calculation, this next slide shows how these amounts are determined. The GR amount of $496.7 million includes estimated amounts for Sporting Goods Sales Tax and the GR Dedicated total of $381.8 million includes amounts to be funded from the Game, Fish and Water Safety Account and the State Parks Account. And keep those numbers in mind as I go over the next slide.

This next slide is a summary of the base request and exceptional items by method of finance and full-time equivalents, or FTEs.

The first line is the base request that is slightly over $1 billion. You’ll notice the General Revenue and General Dedicated amounts in column 2 and 3 tie to the base amounts tied to the prior slide at $496 million and $381.8 million. Federal funds in column 4 and other funds in column 5 consist of various appropriated receipts, license plate funds and various collections, and these are not capped. These are based on our agency’s best estimates.

Baseline full-time equivalents are requested at the current cap amount of 3,160.9. Moving on to the second line item, additional FTEs of 106. These items are for additional FTEs for state park-related purposes. And this is only a request for authority and not additional funding, so we’ll use current funding to fund these additional positions.

Next is a summary of our exceptional items in the amount of $238 million and 38 FTEs, which I’ll go into more detail in a later slide. This brings the total request to $1.2 billion. As previously mentioned, fund balance concerns is why we’re asking for the majority of the request as General Revenue.

Going over some of the baseline funding highlights. Divisions are funded at 100 percent of FY ‘24‑’25 operating base at least at this point in the process since there were no mandated budget cuts in the instructions. Also in the base is capital construction major repairs related funding of $115 million with $92 million for state parks-related projects and $23.2 million for Fund 9-related projects.

As mentioned, next is the schedule of our exceptional items in priority order.

Item 1: Capital Transportation of $14.8 million.

For the replacement of non-law enforcement vehicles that I mentioned there were that were removed from the base, this will cover 283 additional vehicles.

Item 2: Critical Repairs of Headquarters of $24.1 million.

The Austin headquarter building dates from 1976 and is in need of critical repairs including replacement of HVAC units original to the building, ADA facility upgrades, and building modernization.

Item 3: Employee Compensation for $69.8 million.

This is to provide targeted salary actions for TPWD employees excluding Schedule C, which is law enforcement, where salaries are  below the same classification as other Article 6 or natural resource agencies.

Item 4: Expand and Modernize Game Warden Presence.

This exceptional item requests $78.1 million and 30 FTEs to expand and modernize the game warden presence across the state.

Amounts would provide funding for ongoing aircraft operations, body camera data storage, game warden computers, vehicles, in-car automation, including the implementation of e‑ticketing, enhanced boater education and capital construction for the Game Warden Academy and other LE facilities across the state.

Item number 5: Agency Technology Modernization.

Our fifth exceptional item requests $7.8 million for projects identified during a recent initiative examining critical agency modernization needs for expansion and improvement of agency network, expanding data services, procure low code applications, RPA or robotic process, and software procurements.

Item 6: Access/Conservation of Fisheries and Wildlife Resources.

We’re requesting $6.3 million and six FTEs to maintain and improve access to conservation of fisheries and wildlife resources utilizing TPWD dedicated funding sources to be used for growing saltwater hatchery productions, expanding hunting, fishing opportunities and keeping freshwater facilities in good working condition.

And our last item, number 7, is Texas Farm and Ranch Lands Conservation Program.

For this exceptional item, TPWD requests an additional appropriation of $30 million and two FTEs over the biennium to increase grants awarded for the purchase of long‑term conservation easements to address the landowner demand. This is in addition to the $2 million that is currently in our budget.

And next I’ll go into some of the steps as far as the remainder of the process. As I mentioned, we submitted our LAR in September, we had a Joint Budget Hearing in October with legislative oversight staff. Currently that staff is analyzing our budget, looking at our base request and our exceptional items. They are basically determining if and what amount of exceptional items will be included in the bill. They can include all seven, none or any combination of that.

Once they finished that analysis, it will be incorporated into the introduced version of the bill which comes out in January.

Then, we’ll have an opportunity to examine that budget.

And if some of the items weren’t funded, we’ll have another opportunity to maybe add those items again if we feel strongly enough about it. From that point, we’ll go into our… we’ll have an opportunity to present our budget at Senate Finance Committee and House Appropriations Committee to give us one more opportunity.

From that point, it will go into what’s called Conference Committee and they will deliberate and they’ll match the Senate version and the House version. And from that point, once they agree on that, then the Conference Committee becomes the General Appropriations Act, and we start the process all over again.

And this concludes my presentation. I’ll be happy to take any questions at this time.

CHAIRMAN HILDEBRAND: Thank you, Reggie. Any questions by the Commission for Mr. Pegues?

VICE-CHAIRMAN BELL: This is Commissioner Bell. One question, did the Comptroller’s Office ‑‑ I know normally there is something sent out about what we’re dealing with on overall budget. Has that document come out yet?

MR. PEGUES: Yeah, you are referring to the Biennial Revenue Estimate. That has not come out yet, but that typically comes out towards the beginning of session.

The way it impacts us is one of our line items is Sporting Goods Sales Tax last biennium. So, we are appropriated 93 percent of what’s for Sporting Good Sales Tax. Last session, the BRE number was actually higher and so we got an additional amount of Sporting Goods Sales Tax, and also some other items based on those estimates. And that’s one of those items when they do the Conference Committee, or when they do the Introduced version of the bill, they’ll take that into account.  If there is an increase, they will automatically add that increase into our budget. It’s required to be at the beginning of session. So, we haven’t reached that point yet.

VICE-CHAIRMAN BELL: Thank you. I thought maybe I had missed something. Thanks for letting me know I haven’t.

CHAIRMAN HILDEBRAND: Great. Any other questions? If not, I want to thank Reggie and the team for all the hard work you’ve put into developing the budget. You know, there’s a lot of work ahead in dealing with the Legislative Budget Board. We will certainly expect some adjustments to the exceptional items as things progress. So I’d ask that you really stay on top of those changes, keep both me and the Commission updated as the process unfolds. And finally, I want to make sure the agency remains a responsible steward of taxpayers’ dollars, and that will continue to be our top priority.

Even though the State of Texas is probably going to have a record surplus this year on its budget, that doesn’t mean we should just spend it all, from my perspective. We need to ask what we need, and we need to ask for no more. And I would ask that you and the team dig into this and with the overarching element of being fiscally responsible and conservative in terms of how we run this agency. Because it is important to the State of Texas, and it’s what we do: we try to run a lean government. So, anyway, but thank you for the work. Appreciate it.

MR. PEGUES: Thank you for the kind words, and we will keep that in mind.

CHAIRMAN HILDEBRAND: Thanks, Reggie. All right.

Work Session Number 3: Internal Audit Update.

Ms. Brandy Meeks, please make your presentation.

MS. BRANDY MEEKS: Good morning, Chairman, Vice-Chairman, Commissioners.

For the record, my name is Brandy Meeks. I am the Internal Audit Director.

This morning I would like to update you on last year’s and this year’s Internal Audit Plans, as well as recent External Audits and Assessments.

So, this and the next slide, show the status of last year’s internal audit plan. As you can see, we are trying to complete that plan, working very diligently. We are currently in the field work phase for our Cloud Computing Cybersecurity Audit.

We are in the fieldwork phase for our Co-Op Recreation Grants Audit, and in the reporting phase for our External/Public Safety Program(s) Audit.

We have also finished the Follow-up for Q4 of Fiscal Year ‘24.

As far as Fiscal Control Audits are concerned, we are finishing those up. We have just started the planning phase for the San Angelo State Park Fiscal Control Audit. We are in the reporting phase for the Lake Casa Blanca and Meridian State Park Audits.

And we have completed the Government Canyon Fiscal Control State Park Audit. We have also… we are wrapping up the Brownsville Law Enforcement Office Fiscal Control Audit.

This and the next slide show the status of our current audit plan. We have not yet started our Assurance or Cybersecurity Projects, but we have made headway in our advisory and our administrative and other projects. We have attended a BRITS Rewrite Steering Committee meeting. We have also completed the Chapter 59 Law Enforcement Seizure and Forfeiture Review.

We’ve also completed the Internal Audit Annual Report, and we are working on a special investigation with the Law Enforcement Division right now.

As far as External Audits and Assessments are concerned, since the last time we met, we have… they have completed the Comptroller’s Post-Payment Audit, as well as the Department of State Health Services Audit of the Corona Virus Response and Relief Supplemental Appropriations Act Funding.

And there are no ongoing external audits and assessments at this time. And I’m available for any questions if you have any.

CHAIRMAN HILDEBRAND: Commissioners, any questions of Ms. Lofye?

VICE-CHAIRMAN BELL: This is Commissioner Bell. One. Brandy, are we comfortable on staffing right now?

CHAIRMAN HILDEBRAND: Sorry, I meant Ms. Meeks. I apologize.

MS. MEEKS: Yes, sir. We are fully staffed. And I am very proud of my team. They are working very diligently getting up to speed with our shop. So, it’s going really good. Thank you.

VICE-CHAIRMAN BELL: Okay and just to the Internal Audit staff, I don’t know who may be here. We appreciate you all, too.

MS. MEEKS: Kelly Devenney, she is our State Park guru.

VICE-CHAIRMAN BELL: There you go. Thank you for being here, ma’am.

CHAIRMAN HILDEBRAND: Thank you, Ms. Meeks. I apologize on that. Great work. And thank you as well. All right.

MS. MEEKS: Thank you.

CHAIRMAN HILDEBRAND: Okay. Work Session Item Number 4: Job Order Contracting, Delegate Authority for Approval of Contracts Over $500,000, Recommended Adoption of Proposed Rule.

Ms. Andrea Lofye.

MS. ANDREA LOFYE: Yes, sir. Thank you, Chairman, Commissioners, Dr. Yoskowitz. For the record, my name is Andrea Lofye, Director of the Infrastructure Division.

And this item is Job Order Contracting and the Delegation Of Authority for Approval of Contracts Over $500,000.

Job Order Contracting, or JOC, is an alternative procurement method. It’s used to expedite maintenance, repairs and minor construction. With this procurement, delivery times, types and quantities are indefinite.

We published a request for a Competitive Sealed Proposals for JOC contractors in May of 2024. This solicitation is for a $50 million program, an initial $20 million program plus three $10 million renewal options, and multiple contracts were awarded in September. This was after the Commission in august authorized us to move forward with major contracts.

At your direction, we published in the Texas Register a proposed amendment to rules governing department contract practices for projects greater than $500,000. The proposed amendment would delegate authority to the Executive Director to award JOC jobs, tasks and purchase orders in excess of $1 million or greater, and it would delegate the authority to the TPWD Infrastructure Division Director and the Deputy Director for those awards that are in excess of $500,000, but not more than $1 million.

Government Code requires the governing body of an entity to approve each job, task or purchase order that exceeds $500,000 in value. This same chapter also allows the entity to delegate its authority, and this delegation would bring the JOC program consistent with our other capital construction contracts.

As of 7:00 a.m. this morning, there were five responses. Four are in agreement. One is in disagreement; however, the comment for that disagreement is that it supports the delegation but encourages oversight.

Staff requests this time be placed on Thursday’s agenda for public comment and action. And I’m happy to take any questions.

CHAIRMAN HILDEBRAND: Any? Commissioner Scott.

COMMISSIONER SCOTT: One thing I’d like to ask, and David this might even reach over to you since you are over everybody, it has been brought to my attention by contractors I happen to know that in– and having been a contractor all my life I understand this business pretty well– one thing I would like to make sure that we are doing as an agency, particularly now that we have got some funds to spend to upgrade and to do these projects, is that we have enough people to be doing the inspections and to be doing and getting the pay orders submitted to us and handled in the shortest period of time. I understand we have the rules and regulations, but for us to continue getting good qualified and cost-effective bids, we have to do our part to get them paid. So I just wish to whomever… internally, y’all need to do that. I just ask that you all please look into that because we need to do that. Thank you.

MS. LOFYE: Yes, sir. And if I could comment on that, we have expedited those processes. In fact, we are bringing in third party inspectors now to help with that. We also during Covid and the couple years after Covid, we were not fully staffed with our inspectors. We now are. And those are our master plumbers, those are our master electricians. So, a very accomplished, very skilled task are staff who works in that area. And we’ve streamlined the process.

COMMISSIONER SCOTT: Thank you very much.

MS. LOFYE: Thank you.

CHAIRMAN HILDEBRAND:  Great. Any other questions for Ms. Lofye? If there are no further questions, I’ll place this item on the Thursday Commission Meeting agenda for public comment and action. Thank you, Ms. Lofye.

MS. LOFYE: Yes, sir. Thank you.

CHAIRMAN HILDEBRAND:  Work Session Item Number 5: Rule Review Recommended Adoption of Proposed Changes to Chapter 51.

Ms. Laura Carr, please make your presentation.

MS. LAURA CARR: Good morning, Mr. Chairman, Commissioners.

I’m Laura Carr, I’m an Assistant General Counsel for the Department.

And this presentation will be about the recommended option of proposed changes arising out of the first round of rule review.

As Dr. Yoskowitz mentioned this morning, we are undergoing the rule review process, and this process is to determine whether our rules and the reasons for initially adopting them continue to exist.

It also gives us the opportunity to make minor housekeeping type changes to those rules.

The first group of rules that we looked at was Chapters 51, 52, 55, 60 and 61, and we are only proposing changes to Chapter 51.

The first proposed change relates to Section 51.61 regarding Enhanced Contract Monitoring. Our current rule lists 16 factors the Department will consider when determining a contract will require enhanced monitoring. The Comptroller’s Office, which oversees the state procurement and contracting process, has directed us to consider additional factors and will presumably make similar requests in the future. Therefore, we propose adding some catchall language to the rule allowing the Department to consider additional factors that it determines appropriate to make the process not only more effective, but also to prevent staff from having to keep coming back before the Commission each time they want to add an additional factor.

The second proposed change is to Section 51.168, regarding Nonprofit Partnerships to Promote Hunting and Fishing by Resident Veterans. This is a minor change to align the abbreviations used in that chapter. That rule has an abbreviation of “NPP” for “nonprofit partner”. We’re proposing to change that to “NP”, as you see there in yellow, to again align that with the abbreviation that are used in the other rules.

Then finally, we are proposing to repeal Section 51.301(a), which is a rule related to the disclosure of customer information.

Several years ago, the Legislature made various changes that impacted the Department’s ability to disclose its customer information. As a result, we repealed multiple rules. Subsection (a) was one of the provisions that was voted on for repeal, but due to an administrative oversight it remained intact.  Therefore, we’re proposing to actually repeal it this time because it is no longer relevant due to those legislative changes.

As of this morning, we actually received eight public comments, seven agreed completely, one disagreed specifically with the proposed change to the enhanced contract monitoring change. That commenter believes that the change should be highly audited to prevent government abuses in awarding contracts.

And I believe that the proposed change will actually align with the commenter’s concern because it will make our monitoring process more effective and more efficient. We are requesting this be placed on tomorrow’s agenda for public comment and action. With that, I will answer any questions.

CHAIRMAN HILDEBRAND: Any questions for Ms. Carr? If not, I’ll place the item on the Thursday Commission Meeting agenda for public comment and action. Thank you, Ms. Carr.

Work Session Item Number 6: Rule Review, Request Permission to Publish Proposed Changes in the Texas Register, Chapter 53 And Chapter 69.

Ms.  Carr, please make your presentation.

MS. CARR: Again, I’m Laura Carr, I’m an Assistant General Counsel for the Department.

And continuing with our Rule Review items. This is going to be permission to publish proposed changes arising out of the second round of rule review.

So, our second group of chapters that we reviewed, Chapters 53, 59, and 69. And again, this is the opportunity to make minor changes to those chapters.

We are proposing changes only to Chapter 53 and Chapter 69.

The first proposed change is to Section 69.304 and Section 69.305. We are changing “pronghorn antelope” to just “pronghorn”, which you’ll see in yellow. This is an ongoing effort by the Department to change that terminology throughout its rules because a pronghorn is not actually an antelope.

Our next proposed changes to Section 69.4, just to correct a numbering error in the rule, which refers to an incorrect number of paragraphs. You’ll see there again in yellow; we will be correcting the number to correctly reflect what’s in the rule.

Third, we are proposing to update the names of endangered and threatened plants listed in Section 69.8. Those changes again are in yellow. Those are the updated scientific names that will be correctly reflected in the rule.

Then finally, we are proposing changes to Section 53.10 and Section 69.305 to update the name of the accrediting entity that’s listed in the rule. It will correctly say “Association of Zoos and Aquariums.”

We are requesting permission to publish these proposed changes in the Texas Register for public comment. And I will take any questions. Thank you.

CHAIRMAN HILDEBRAND: Questions? If not, I’ll authorize staff to publish the rules in the Texas Register. Thank you very much, Ms. Carr.

Work Session Item Number 7, Cultivated Oyster Mariculture Program Rule Revisions, Recommended Adoption of Proposed Changes.

Dr. Lindsay Glass Campbell, please make your presentation.

DR. LINDSAY GLASS CAMPBELL: Good morning, Chairman, Commissioners. For the record, I’m Dr. Lindsay Glass Campbell.

I am the Cultivated Oyster Mariculture Program Coordinator in the Coastal Fisheries Department, or Division.

Today I’ll be presenting proposed amendments to the Oyster Mariculture subchapter with recommendation for adoption. For those that may not be as familiar with the Cultivated Oyster Mariculture Program, or COM, as we commonly abbreviate it–  and I will use that term throughout this presentation– in May of 2019, the 86th Legislature authorized House Bill 1300 which created Parks and Wildlife Chapter 75 and delegated to the Parks and Wildlife Commission the authority to regulate the process of oyster mariculture in Texas. This allowed mariculture to become a new industry in Texas, and Texas was the last coastal state to allow this in our country.

In turn, the Department in 2020, adopted the regulations, the first and current regulations governing oyster mariculture.

The first COM permit was issued in July of 2021, with the first harvest occurring in April of 2022.

Oyster Mariculture industry provides both an economic and ecological benefit to our coastal region. Currently, we have 12 grow-out sites often called “farms” where oysters are grown out and harvested for consumption. We have an additional 31 of those sites in conditional status whereby they have been approved by TPWD but they are gaining their other agency authorizations before activities can begin.

We have two nurseries and two hatcheries. And this is where oyster are grown, spawned and grown in early life. Since harvest began, over… well now, based on my most recent numbers of harvest reports, 1.75 million oysters have been harvested.

Now COM oysters are singles, they are not sold in sacks.

The current ex vessel value per oyster is $0.68.

So, when the regulations were first adopted, this was a brand‑new program in Texas and the Department was aware that as the program and the industry developed, there would probably be a need to revisit and refine and modify the rules. The goals of these proposed revisions are really to clarify and refine the program rules, which will in turn improve programmatic efficiencies, reduce regulatory burden both on COM industry members and the Department.

And this was based on extensive communication and input from our industry members, the Department biologists and our game wardens, plus guidance from the Texas Department of State Health Services and the National Shellfish Sanitation Program, abbreviated, NSSP, which are the guidelines governing oyster health and safety as recognized by the FDA.

So, a roadmap of where we’re going and the major topics that I am going to cover: The issue of where farmers can tumble and sort oysters; Then allowance for permit transfers; proposed extension for the sunset provision regarding oyster genetic integrity; a proposed reduction in mariculture oyster harvest size; then a group of changes that are more clarifications of existing regulations; and finally, we’ll cover sections proposed for repeal mostly due to other proposed changes.

Tumbling and sorting is a common oyster mariculture practice which uses a mechanical process that separates oysters according to size. In addition, this cleans the oysters and promotes a uniform shell shape in that deeper cup. These pictures show examples of one of the machines used for this. As the tube rotates, the oysters go down and fall through the different size holes and collected in the bin underneath. Many of our permittees perform this activity on their boats on the water in their permitted areas. However, our bays and estuaries of Texas due to wind and wave action, sometimes this process is not safe or feasible to do on the water. So, permit holders requested that they be allowed to temporarily remove oysters from their permitted site to shore to conduct this process. The Department saw that this was reasonable to allow, provided that the oysters were returned to their site prior to harvest. Currently regulations are silent on tumbling and sorting either way. The proposed amendment would codify a mechanism for oysters to be temporarily located for tumbling, sorting from their permitted area.

We propose to allow COM permits to be transferred. After listening to feedback from our… the COM community, the Department considers that because these permits have a ten‑year term and that the activities from these permits result in business ventures, that there’s likely during that period, ten‑year period, times when due to business activities ownership may change. Therefore, we’ve determined that the transfer of permits would be reasonable and less disruptive to the locations. The proposed amendment would provide that permit holders could apply for this transfer with a $200 transfer fee, which is the same as an application fee, but all the permit provisions, conditions, and effective dates would stay the same.

Our regulations specify that oyster seed, or baby oysters as you can see in this picture, for mariculture must be produced by Texas broodstock grown in Texas hatcheries. This includes a so-called “sunset provision” that allows the use of a non‑Texas tetraploid line and the use of out-of-state hatcheries before the sunset date in 2027 with the intention after that date the industry would have developed enough that we could revert to this Texas-only regulation.

The development of the Texas origin tetraploid line is being conducted outside of the Department by researchers in the industry. Currently they do not expect that the full development, plus stabilization of that line and distribution of the line, will occur by the sunset date. Additionally, while we have two hatchery groups within Texas, currently only one of those has a large commercial scale production. Based on these factors, we propose to extend the sunset date to 2033 to allow for this burgeoning industry to establish a more robust infrastructure.

We propose changing the size limit of COM oysters from 2 ½” to 2". The original limit was based on both the predominant market size, and that’s still the predominant market size, and to ensure that oysters could be distinguished from undersized wild oysters.

Consulting with our staff and especially our game wardens, as we’ve gotten to know this industry and seen hands on what these COM oysters look like produced in Texas, we’ve determined that these can be readily distinguished from wild oysters. And so, the minimum size limit can be reduced, which gives farmers more flexibility for some other markets and opportunities to meet the market demand for a variety of sizes. The proposed amendment additionally creates a 5 percent cargo allowance for undersized oysters which mirrors what is in place for wild oyster harvest.

Now onto our clarification section. Because many of our oyster hatcheries also function as nurseries, it would be more efficient to group these in one permit type. So, we propose changing the name of the COM Nursery Only Permit to the COM Nursery-Hatchery Permit and expanding the text to include hatcheries activities such as producing broodstock… or producing seed from broodstock.

We want to refine our current text surrounding oyster seed that is grown in prohibited or restricted waters to harmonize with the language of the NSSP, which as a reminder are the federally approved guidelines over oyster health and safety. This will help reduce any confusion about variation between the two sources. To reiterate an important health and safety requirement specified by the NSSP, we propose to explicitly specify that oysters that are out of the water for any reason– be that desiccation, tumbling and sorting, splitting bags– that oysters that are out of the water longer than the time to temperature control limits established by the Texas Department of Health, must be resubmerged for a minimum of 14 days prior to harvest for raw consumption. This allows the oysters to purge contaminants. Now, you can see we have some yellow text on here, and we request the addition of that text highlighted in yellow, as it came to our attention after we presented at the August Commission Meeting that there are some cases, while this is really rare in oyster mariculture, when oysters that are harvested and tagged for shucking and post-harvest processing where that two‑week re-submergence requirement is not needed.

The addition keeps the intent of the regulation ensuring the safety of the products that could be consumed raw without prohibiting an NSSP‑approved type of harvest.

Next, we want to contemporize the way our permit holders can be contacted should their gear be found by adding the option to use a contact phone number on gear tags. We proposed to revise text on processes already outlined in the rules but add clarity for the process of adding a subpermittee to the permit and the process of obtaining the Oyster Transport Authorization, which is the documentation that they need when moving oysters that are not harvest tagged around the state. That creates the paper trail, shows ownership of those oysters.

And to make our COM public meetings more efficient, we propose that COM public meeting notices be effected via the Department’s website, and adding the option for a virtual hearing.

Our final clarification creates a COM Harvest Authorization. This is an annual authorization that more clearly meets in a visible way the guidelines that harvest authorizations only be for a one-year period required by the NSSP by having that yearly date range on that authorization. While we already have internal processes that are compliant with NSSP, for this we want to ensure that there is no misunderstanding should somebody see our COM permit which has that ten-year effective date and confuse that with yearly harvest authorization. This will be issued annually to our Grow Out Permit holders and will not result in any new requirements or additional fees for those holders.

The final topic I am going to cover are repeals. First, the rule concerning Oyster Seed Hatchery with the proposed changing and streamlining of the Nursery-Hatchery Permit, this will no longer be needed. Next, we propose to repeal the rule within this chapter concerning the agency’s Decision to Refuse to Issue or Renew a Permit. Now these processes aren’t going away. They are just going to get a move. We propose to add COM to the list of licenses and permits covered by Chapter 56 which contains the Department’s uniform processes for these activities.

Finally, our Prohibited Acts section. The majority of that text is redundant to text already in the General Provisions. The two non-redundant items would be distributed within the General Provisions. So, rest assured that anything that was already prohibited will continue to be prohibited.

Okay, now taking a breath after getting down in the weeds, which, you know, with oysters, they are are covered by multiple agencies and that intersection; so, taking a step back in bringing it into focus that these proposed revisions are to clarify and refine program rules, increase efficiencies, and, you know, based on the feedback from our industry members and our staff and those involved in the COM industry.

To gather public comment, we held a virtual public meeting on October the 9th. 11 people attended and four gave verbal public comment at that meeting. Since then, we have a now total of 16 comments in agreement. Two of the agreeing comments mention reduction in the permit fees. Eight agreeing comments request the use of Gulf of Mexico-only triploids. And the agency received unanimous support from the Coastal Resource Advisory Committee and the Oyster Advisory Committee. And the GLO Federal Consistency Coordinator determined that the proposed revisions are still consistent with the Coastal Management Plan. The agency additionally received organizational letters from the Texas Press Association regarding disagreement with removing the requirement to publish in the newspaper.

The Texas Oyster Mariculture Association and the East Coast Shellfish Growers Association requesting a revision to allow the use of a non-Texas parent triploids from the Gulf of Mexico.

And the Texas Aquaculture Association was in support but requested the use of Gulf of Mexico triploids and to reduce fees to a $450 flat rate.

With this summary, the staff requests that this item be placed on Thursday’s agenda for public comment and action with the additional text change. With that, I will take any questions.

CHAIRMAN HILDEBRAND: any questions for Dr. Campbell?

COMMISSIONER DOGGETT: I do. Leslie Doggett. Dr. Campbell, first, this is very exciting and meaningful stuff that you’re doing with the oyster population. Thank you. Thank you for all that.

I enjoyed your presentation. Just for basic information stuff, it was real interesting when you had the slide that had the tetraploid and the fully developed oyster in it. How long does that take for tetraploid to fully develop?

DR. CAMBELL: The tetraploid line?

COMMISSIONER DOGGETT: Yeah.

DR. CAMPBELL: That is really dependent. You know, kind of the estimate was six to eight years. So, there’s very… a lot of steps for that tetraploid line. First, they gather the seed, they kind of do some chemical induction to produce triploids.

And from those, find ones that are non-sterile that can produce.

Then those that do produce, are their gametes viable?

So, then they have those, and then, they have to breed those to get that. So, you have that triploid, which is three chromosomes. And then you get tetraploid. You have to breed those to get four chromosomes. And then from those, you have to find those that are… can produce gametes. And then even those, gametes that they produce are viable. They find that. Then once they have sort of found some of those, that’s where it gets into that stabilization making sure‑‑ they are somewhat fragile, more fragile, than, say, normal oysters. Stabilize that line and be able to replicate it. So that’s kind of that process is there’s the ideal that, oh, yeah, you could go six years in genera, but it can go a little longer if you have a crash or the oysters produce seasonally. So, if this first batch you didn’t find what you need, then they have to go to the second batch. Then again, then talking with the industry members that stabilization, then they have to replicate that, then getting it distributed to the various hatcheries that would use them, those hatcheries getting up on the techniques.

CHAIRMAN HILDEBRAND: So, once stabilized, then fully developed is how long?

DR. CAMPBELL: Let me see. Probably another two years.

COMMISSIONER DOGGETT: Couple of years.

DR. CAMPBELL: Yeah, because it takes…  they have to have that…

COMMISSIONER DOGGETT: You said we had was it one, I’m trying to remember, 1.7 million oysters farmed?

DR. CAMPBELL: Mm-hmm.

COMMISSIONER DOGGETT: In a pretty short period of time.

Two years. That’s with nine farms, is that what we have?

DR. CAMPBELL: Right now, currently producing and harvesting are seven of our farms.

COMMISSIONER DOGGETT: Seven farms. And what is the Department’s expectation on that? How many farms would we like to see out there in the Gulf?

DR. CAMPBELL: Well, you know, TAC doesn’t limit the number of farms. Right now, since it’s so new, I don’t think we’re anywhere near our carrying capacity. In the future, we may need to revisit that as it grows. But, as I said, there are 31 farms in that conditional. A group of those, about 20, are a coalition of wild harvesters, shrimpers, that are working to kind of look at this opportunity, maybe move out of this. They are in that conditional phase with gathering other permits, probably looking at a year before they are up and running. So, I think it’s just still a growing industry and our farmers meeting the demand… you know, working to meet that demand that they are getting.

COMMISSIONER DOGGETT: So that $0.68, that’s an interesting number. Per oyster, is that wholesale number?

DR. CAMPBELL: Yes.

COMMISSIONER DOGGETT: Is that what the farmer gets?

DR. CAMPBELL: Yes. So, that’s over… When they submit harvest reports, also kind of divided, they can sell to another dealer, they can sell to a restaurant, or they can sell to individuals.

If they’re certified by the Health Department selling to individuals, they are getting anywhere between $0.80 to $1 or more. Selling directly to restaurants, $0.74 is the average.

And, then when they sell to a dealer, another dealer, that middleman, it’s a bit lower. But overall, that’s…

COMMISSIONER DOGGETT: Would you know if this model is currently economic for the farmers? Are they making money or do they have to put in capital to keep them going until they make money? Where are the economics on this now?

DR. CAMPBELL: I am not privy to their economics.

COMMISSIONER DOGGETT: You don’t have visibility to the financials on that?

DR. CAMPBELL: No.

COMMISSIONER DOGGETT: Anecdotally, what do you hear on the economics?

DR. CAMPBELL: That, you know, there is getting past those first startup costs with your gear and your seed, but they are continuing. They are being successful. So, that they are excited about where it’s going, and they’re finding their market.

COMMISSIONER DOGGETT: So, I know you said 31 is in the current plan. So, is there any expectation for the quantities of oysters that can be farmed in total? Or is it just sort of a step, we’ll see as we go?

DR. CAMPBELL: See as we go. When farmers start, you know, if they have a two-acre or ten-acre plot, they may for the first years they are not going to necessarily build out that whole plot, so it’s kind of hard. Then, it also depends on their individual business plan of how far they space cages, the density in there, and then even within their cages, how dense they keep oysters. So, it’s a little hard to project.

COMMISSIONER DOGGETT: I just want to thank you for your work on this front. This is really exciting stuff. Appreciate it.

CHAIRMAN HILDEBRAND: Great. Thank you, Commissioner Doggett. Any other questions for Dr. Glass? I’ve got a couple. So, mariculture vs. kind of natural or standard reef harvesting, do you have any idea on the volume of, is it the number of oysters or pounds? Is that the unit that you used? Is it just number of oysters per…?

DR. CAMPBELL: So, for mariculture, they report in the number of oysters. Now, we are currently doing a meat weight study to kind of get that conversion factor which is used with the wild harvest. They report sacks, and it’s estimated, well, this many sacks, that was the total weight, then you get a meat weight from that. So, we’re working on that. But it is more difficult, apples and apples comparison, just by how harvesting is packaged and reported.

CHAIRMAN HILDEBRAND: Okay. So I’m going to ask you a couple of questions, and you’re not going to have all the answers, so but you can get back with us on this. One is I’d like to see the relative volume of mariculture versus kind of… wild natural harvest in Texas waters today. You don’t have to answer today, but maybe you’ve got the answer.

DR. CAMPBELL: Okay. Well, so the total sacks last year, the ’23‑’24 season for wild harvest if you include public reefs and private reefs, total sacks 223,000. And if you say a sack has 260 oysters in there. So, it’s just a magnitude (inaudible) but the area covered by our wild harvest is much greater than what’s covered by our farms. So…

CHAIRMAN HILDEBRAND: So, 223,000 sacks times 200, that’s the take in 2023?

DR. CAMPBELL: Uh,’23-’24. Yeah.

CHAIRMAN HILDEBRAND: ’23-’24. And in that same period of time, what do you think if you want to equate it to sacks, how many sacks do you think we did from a mariculture standpoint?

DR. CAMPBELL: Okay. So, we’d look at about 750,000 divided by 200.

CHAIRMAN HILDEBRAND: 150. Okay. So, 6… alright.

MR. ROBIN RIECHERS: Chairman, Robin Riechers, Director of Coastal Fisheries. It’s 46 million is what she gave you for the wild harvest on individual oysters basically to about 1 million oysters which she said was the harvest in that year. So,

CHAIRMAN HILDEBRAND: 46 million wild…

MR. RIECHERS: …to about 1 million currently raised…

CHAIRMAN HILDEBRAND: versus 1 million. Got it.

MR. RIECHERS: Yes.

CHAIRMAN HILDEBRAND: So, it’s in the fledgling stage of the industry. And so, another question, and Robin maybe you can stay up here, what do you think the likelihood is someday we become a mariculture driven oyster producer versus kind of taking down reefs in our coastal bays?

MR. RIECHERS: Certainly, in the Chesapeake and on the East Coast, that is kind of where industry has moved towards, but that is because they basically lost their wild harvest. Here with our abundant opportunity still for wild harvest both in public reefs as well as with the opportunities on private leases as we called them, certificates of location, certainly there could be a move to that direction but as long as those opportunities in the public harvest area are there, these oysters are really filling different markets. So, I would say that there would not be a drift, if you will, of the businesses in that direction as long as there’s still an opportunity to harvest in the public reef areas.

CHAIRMAN HILDEBRAND: Because I assume the cost to harvest off the reefs is much lower than mariculture?

MR. RIECHERS: Certainly. There are certainly costs of boats, fuels, people, et cetera, but if you have the opportunity for the price of a license to harvest, it’s probably going to be a preferred alternative or a complementary alternative because some businesses may choose to be in both arenas.

CHAIRMAN HILDEBRAND: Right. Okay. Good. Do we know… I’ve heard, do the mariculture oysters taste better because they are not in the mud line?

DR. CAMPBELL: You’re trying to get us in trouble.

CHAIRMAN HILDEBRAND: No, it’s just a question, and it’s an opinion you have.

DR. CAMPBELL: They taste different. So, since they are in the upper water column they are getting more of the photosynthetic green algae and things. It’s just a different taste. Some people equate it to a sweeter taste. So, it is personal preference.

CHAIRMAN HILDEBRAND: Okay. Couple other questions. Is there an issue with handwashing versus power washing these mariculture oysters? I’ve heard it’s a very labor-intensive issue to hand wash them versus a power wash?

DR. CAMPBELL: So, that is covered under the TCEQ permit. So, they have to get a Wastewater Discharge Permit from TCEQ.

Even though these grow-out farms aren’t really discharging, it’s part of the MOU agreement with aquaculture. So, they are a level 5 for this Wastewater Discharge Permit, and it’s under their regulations that stipulate actually no cleaning on the water.

Now, in our estimation, because that we have the buffers we have around them and where the oysters are, we see that it would be a low-risk activity. There was a lot of concern about sedimentation and spreading organisms since these are in the upper water column. We have the buffers from seagrass, buffers from our wild oysters. There’s been a study looking at what happens when power washing.  So, it’s a temporary increased turbidity in the water of organic matter that came from… you know, grew on it, algae barnacles. Both the NSSP and our regulations prohibit the use of harmful-like paints or chemicals on their gear. That was another worry. People worry about that flaking off. But they are not allowed to use any like anti-flaking paint…

CHAIRMAN HILDEBRAND: Sure, but can they get the TCEQ permit to do this?

DR. CAMPBELL: That would be a change in TCEQ.

CHAIRMAN HILDEBRAND: So currently they cannot?

DR. CAMPBELL: Right.

CHAIRMAN HILDEBRAND: And you’re effectively just putting sediment back in the water that was in the water. Anyway, we don’t need to debate that today.

DR. CAMPBELL: It’s not even sediment, it’s organic material.

CHAIRMAN HILDEBRAND: Organic material.

DR. CAMPBELL: Not dirt.

CHAIRMAN HILDEBRAND: So what do you think, — because clearly we want to try to promote this industry– what do you think is the most onerous regulation we’ve got in place now? If I had a bunch of mariculture people here, what would they say is the number one thing that’s preventing them from growing this industry from a million oysters a year to ten million, other than capital?

DR. CAMPBELL: Like mentioned in the public comment, reduction in fees and then the seed supply issue.

CHAIRMAN HILDEBRAND: The what?

DR. CAMPBELL: Seed supply, being able to get that oyster seed.

So, with their requesting Gulf of Mexico triploid, we specify for those triploids, they need to be a Texas diploid parent times a Gulf of Mexico tetraploid. But they are requesting a Gulf of Mexico diploid parent with that tetraploid.

CHAIRMAN HILDEBRAND: You lost me on that one, but that’s okay.

DR. CAMPBELL: The ability to use seed that’s produced in the Gulf of Mexico for other states.

CHAIRMAN HILDEBRAND: Understand. And there’s just not enough hatcheries to provide the seed stock for…  But I suspect if there’s a commercial pull, somebody will fill that gap. So, good. Are you optimistic about the industry?

DR. CAMPBELL: Oh, yeah. I think we’re just at the beginning of it. It’s continuing to grow. There’s been a lot of good… the permit holders contacting local restaurants, the restaurant industries getting the word out about their product, getting their product in restaurants. Since you’re down here in the Gulf‑‑ not in the Gulf but on the coast– you can sample a lot of our local Texas seafood. Fish varieties, oysters from both wild and mariculture here. So, you know, really the coastal communities and even San Antonio, Austin, Houston, those areas are very much embracing these and highlighting these oysters.

CHAIRMAN HILDEBRAND: they are. So, they are putting on the menu that these are organically mariculture driven, non-… you know, sustainable, all of that. Interesting. I know there’s a restaurant here in town that the guy is fully integrated and he’s a mariculture farmer.

All right, well, in final, exciting as Commissioner Doggett, exciting. Ultimately maybe it doesn’t replace but it enhances the current wild harvest. So, I think we need to do everything we can from a regulatory standpoint to limit the amount of overt regulation and make it simple and easy for these folks to create these new farms and create more volume.

Commissioner Doggett, I’ve heard it’s $2 million to $3 million of capital, cap ex, to just start one of these.

COMMISSIONER DOGGETT: Wow.

CHAIRMAN HILDEBRAND: I don’t know if that has any truth to it or not. So, anyway, thank you. Fascinating. Appreciate it very much.

If there’s no further questions, I’ll authorize staff to publish the rules in the Texas Register.

Work Session Item 7—  Excuse me, 8: Statewide Oyster Fishery Proclamation, Temporary Closure of Oyster Restoration Areas in Galveston Bay, Recommended Adoption of Proposed Changes, Ms. Lindsey Savage.

MS. LINDSEY SAVAGE: All right. Good morning, Mr. Chairman, Commissioners. My name is Lindsey Savage, and I’m the Restoration and Artificial Reef Team Lead in the Coastal Fisheries Division.

Today, I will be presenting a recommendation to adopt proposed changes to the statewide oyster fisheries proclamation to temporarily close two oyster restoration sites until November 2026.

Parks and Wildlife Code Section 76 grants the Texas Parks and Wildlife Commission the authority to close an area that is being reseeded or restocked for oysters. Multiple reefs across the state are being planted with cultch material and to restore degraded and lost substrates. A two‑year closure gives the oyster larvae that recruit to the fresh cultch the opportunity to grow to harvestable size and repopulate the reef. Successful oyster restoration projects are dependent on larval recruitment and growth within that first two years. Post-construction monitoring data has shown that our restorations have been successful, and reefs that were closed for two years are still healthier than natural reference reefs up to nine years later.

Here is a picture of the oyster growth on our recently restored and recently reopened site in Grass Island in Aransas Bay. As you can see, the oyster growth creates the reef itself. The two‑year closure allows this structure to develop uninterrupted by dredging activity and allows two cohorts of oysters to recruit to the site and grow to maturity.

In July and September 2024, nine acres of oyster reef were restored on Desperation Reef in partnership with oyster dealers as required by H.B. 51, 85th Legislature of 2017. We plan on using the remaining five acres on Desperation Reef area for additional restoration associated with these H.B. 51 activities in the coming year. This closure would encompass the full 14 acres.

In 2022 and 2023, mitigation efforts consisting of oyster restoration on seven oyster mitigation pads was conducted by the Port of Houston and the U.S. Army Corps of Engineers on Dollar Reef as a result of adverse impacts to oyster reefs resulting from the Houston Ship Channel Expansion Improvement Project.

This closure would encompass 529 acres in total.

This is a close‑up view of the proposed U.S. Army Corps… I’m sorry, I skipped.

This map shows the location acreage of the proposed temporary closure areas outlined in red in the Galveston Bay system.

The northern site there is Desperation Reef with 14 acres and the southern site is Dollar Reef with 529 acres.

This is a close‑up view of the proposed U.S. Army Corps of Engineers’ Dollar Reef Mitigation Closure Area shown outlined in white. Note the seven oyster mitigation pads shown in dark blue range in size from 13 to 20 acres each. The hashed area on the left represents the Texas Department of State Health Services restricted waters and the one and a half pads shown in red within these waters are not included in the proposed closure as they are already closed to oyster harvest. The full restoration area is being recommended for closure as opposed to individual oyster pads to avoid potential confusion that could result from multiple closings in close proximity. The area encompassing the three oyster pads to the west was previously closed to harvest in November of 2022. The proposed closure would expand this closure area to include the four oyster pads to the east and extend the closure period until November 2026. This would allow all restored areas to be open to harvest simultaneously.

The amendment we propose is to temporarily close two restoration areas in Galveston Bay which will then reopen for harvest in November 2026. These proposed changes were published in the Texas Register for public comment on October 4, 2024. As of 9:00 a.m. this morning, seven comments have been received, all in favor of the changes. These changes were also presented to two advisory committees, the Oyster Advisory Committee on September 27, 2024, and the Coastal Resources Advisory Committee on October 29, 2024, and both committees supported the proposed changes.

We are requesting that the proposed item be placed on Thursday’s agenda for public comment and action. Thank you for your time, and I’d be happy to answer any questions you may have.

CHAIRMAN HILDEBRAND: Thank you, Ms. Savage. Any questions for Ms. Savage? Okay. Great, great work. Really wonderful. What do you think the cost of these reef restoration program is?

MS. SAVAGE: In 2020, which is the more recent… past recent data that we had, it pretty much skyrocketed. We were seeing around 120,000 per acre, as opposed to before, you know, 2020, it was around 20,000 per acre. However, we were able to look at reducing costs, opening up opportunities for other potential contractors to bid on our contracts for these projects. One of them opened it up to oyster industry by saying that oyster lovers could potentially go in and do this contract work. One of the contractors was an oyster dealer for this one project, and we were able to reduce costs by about 30 percent or so, just depending on the size inch layer that we use for the reef. So, there are ways we were able to reduce costs. And of course, alternative materials is something we’ll always look into and receive requests from those that are wanting to study them with academic partners and things like that. So, it’s hopeful in the future for sure.

CHAIRMAN HILDEBRAND: Can you… you know, the Rigs to Reefs Program was pretty big for a while. Is there any… will the oysters attach to a metal substrate?

MS. SAVAGE: I’ve seen anecdotal evidence in tin cans. I’ve seen them, you know, attached in bay systems to metal. Any hard substrate has been shown to grow oysters, as long as it’s suitable for the habitat and not deleterious in its effects. As far as our Artificial Reef Program goes, you know, offshore we’re using anything from steel vessels to steel pipes to concrete culverts, concrete pipes, concrete rail ties, things like that. And we’re seeing growth of any type of encrusting organism out in the Gulf attaching to those items.

CHAIRMAN HILDEBRAND: So potentially you could use it in the bay system?

MS. SAVAGE: Potentially yes. And we’ve received a few requests through the GLO and others of, hey, we have this product, or this material of opportunity is what we call them, and they say, “Hey, can we potentially put it in the bay system. Can we open up a near shore site?” So, it’s things we have been receiving requests from, and of course we take each item, make sure it  would be clean and has material testing done so it wouldn’t cause any impacts.

But as far as the Artificial Reef Program goes, it’s mostly been offshore, the near shore areas in state waters and offshore.

Oyster restoration, this is one team now, we’re able to work together and maybe provide those opportunities for bay wide in the future.

CHAIRMAN HILDEBRAND: Well, let’s just try to be as creative as possible and try to drop the cost because you’d love to do this all over the state of Texas.

MS. SAVAGE: Absolutely. And we have, you know, companies that reach out to us which we can’t partner with these companies, they have to do the bidding process, but we are able to redirect them to academic partners so they can test these materials and test the efficacy of it and potentially open them up for bidding on contracts in the future. So, it’s very hopeful. I’m seeing a lot of…

CHAIRMAN HILDEBRAND: Isn’t there a carbon capture element to it as well?

MS. SAVAGE: There is absolutely. Blue carbon for sure. One of our partners down in the UT-RGV area, Dr. Kline, he is studying that on the RGV Reef which has a lot of concrete materials, a lot of donated materials. He is studying that currently. So, I don’t have the results yet, but he’s looking into it.

CHAIRMAN HILDEBRAND: Good. Great, thanks. Thanks for the presentation. Okay.

MS. SAVAGE: Thank you.

CHAIRMAN HILDEBRAND: Yes, sir?

COMMISSIONER SCOTT: Excuse me, I got a quick question for you.

In the past there’s always been discussion on the cost of when we redo these reefs and everything. Remind the Commission, if you will‑‑ and me included, I don’t remember exactly ‑‑ but who all shares in the cost of those reef restorations?

MS. SAVAGE: Are you talking oyster reefs or artificial?

COMMISSIONER SCOTT: Yes.

MS. SAVAGE: Oyster. So, it’s different programs, so different types of fees. With H.B. 51, we have two options. It’s either the dealer placement, so they fund it themselves and place the amount of cultch that they owe back to us through that placement or they pay us a fee to do that for them. So, we potentially have, you know, the oyster dealer funds for that, the fee for that.

There’s the Oyster Buyback Program which also gives funds for that. However, we’re also big into applying for grants. And a lot of our restoration that we do in-house is covered by a lot of grants. We’re applying all the time and receiving a lot of good funding in the future. Also, you know, Harvey disaster grant funding, NOAA Restore grants. So, it’s a mixture of both. Dealer fee placements, buyback, grants, all that.

COMMISSIONER SCOTT: Thank you.

CHAIRMAN HILDEBRAND: Any other questions? Thanks. If there’s no further questions, I’ll place the item on the Thursday Commission Meeting agenda for public comment and action.

Work Session Item Number 9: Oyster Certificate Of Location Rules,  Request Permission to Publish Proposed Changes in the Texas Register. Mr. Zach Olsen, please make your presentation.

DR. ZACH OLSEN: Good morning, Mr. Chairman, Commissioners.

For the record, my name is Zach Olsen, I’m the Ecosystem Resources Program Director for the Coastal Fisheries Division.

Today, I’ll be presenting proposed changes to the Oyster Certificate of Location Program with the request to publish these changes in the Texas Register for public comment.

I’ll start with the brief background of our current Certificate Of Location Program. I’ll be abbreviating that as COL throughout this presentation.

COLs are essentially, currently as they exist, areas for private on bottom oyster harvest. They have historically been associated with what’s termed, “oyster transplants.” An oyster transplant is essentially a process that takes advantage of depuration, which is when oysters are moved from restricted waters into approved or conditionally approved health department waters and allowed to reduce pathogenic organism loadings for direct market. So that’s been the historical use of these areas.

However, modern COLs primarily rely on cultch placement.

That is placement of hard substrates for natural oyster settlement, and then those holders have sole rights to those oysters on those COLs.

Currently the program, as it exists, is only in Galveston Bay.

There are 43 existing COLs. They take up a total acreage of just over 2,300 acres. They range in size from 11 to 100 acres each.

An annual Texas harvest from these COLs ranges from about 9 percent to 36 percent of the total Texas harvest. To give you an idea again of what the program currently looks like, it exists only in Galveston Bay. You can kind of see this is a map of that Central Galveston Bay area. Those white polygons are existing COLs on the landscape.

A couple other program specifics. These COLs can be 100 acre maximum per site. There’s a current 15‑year rental term. There are some siting requirements including the avoidance of natural oyster beds, shoreline buffers, and other site-specific stipulations.

I’ll also say that authorities surrounding COLs, also span into several other state and federal partners, including the Texas General Land Office, U.S. Army Corps of Engineers. I want to recognize a couple of our partners from our General Land Office, Ms. Amy Nunez and Ms. Danielle Devak, I believe are here today.

We’ve been working closely with them as we have been thinking through some of these proposed changes. I just want to thank them for their and their team’s coordination here.

So, a brief overview of kind of how we got to the proposed changes today and then a categorization of what the proposed changes are in Texas Administrative Code.

So, the 88th Texas Legislature modified Parks and Wildlife Code Chapter 76 with the intent of allowing for the use of the COL program for restoration purposes. As I said previously, it currently exists as a tool for harvest. So, the proposed changes to Chapter 76 and those we’ll be talking about today are primarily surrounding the use of these COLs for harvest.

So, the three categories of changes proposed in Texas Administrative Code can be thought about as number one, mirroring changes to Parks and Wildlife Code where that’s relevant. Number two, changes needed for the administration of some of these new authorities in Texas Administrative Code.

And the third is just general modernization of the language for the COL program, kind of independent of some of those changes to Parks and Wildlife Code.

So, four main changes to Parks and Wildlife Code Chapter 76– and I’ll dig into each of these in a little bit more detail on the following slides.

But the first is the change to “natural oyster bed” definition. The second is the allowance of siting COLs on what’s termed “degraded reef.” The third is the removal of that depuration term from the consideration during COL renewal. And the fourth is a section of Parks and Wildlife Code of 76.002 which establishes broad authority for the Commission to set various aspects of the COL program for restoration purposes. So, we’ll dig into each of these in a little bit more depth.

So first off, this change to the “natural oyster bed” definition, you can see the previous and the current definition given on your screen there. The main change here is that the previous definition relied solely on the presence of a certain number of live oysters across that reef landscape while the current definition more so speaks to the predominance of oyster shell or live oysters in those substrates. So taking advantage or taking into account some of these other important reef components we know to be ecologically important for oyster reef.

And I’ll describe why that’s important in the context of restoration here.

Also, this next change to Parks and Wildlife Code, the allowance of siting COLs on degraded reef. Previously, a COL could not be sited on a natural oyster bed but now you can see with this new provision the Department may subject a natural oyster bed to location if that bed is determined to be degraded. And there’s several stipulations given there to consider including the relative abundance of live oysters, availability of natural cultch material, sediment overburden, the amount of time the area has been exhausted, and any other area criteria indicative of degradation.

So between this and the change to the “natural oyster bed” definition, the idea there was to open up some areas that would be of interest to restoration practitioners. When we talk about restoring oyster reef, we’re typically talking about restoring on historic oyster reef and on degraded oyster reef. Between these two changes, the thought is it would open up some areas for COLs for restoration.

The next change is that removal of that depuration term and that consideration of depuration from the COL renewal process, that’s for both COLs for harvest and restoration. As I mentioned earlier, COLs were historically used for depuration, but that’s not a common practice anymore. It was removed from the renewal process just to make that process a little bit more straightforward, and obviously this wouldn’t be a consideration for restoration COLs as well.

Then lastly, this change to Parks and Wildlife Code 76.002, establishes broad authority to the Commission to establish several aspects of the COL program related directly to COLs for restoration, including things such as fees, application requirements, lease terms, et cetera. To note, a lot of these aspects of COLs for harvest are currently codified in statute and are defined in statute for COLs for harvest. But here that authority is given to the Commission specifically for COLs for restoration purposes. We’ll talk about some proposals there.

So, moving into Texas Administrative Code, these first proposed changes are those changes that would really just directly match language in the Parks and Wildlife Code.

The first is matching the “natural oyster bed” definition. The second is adding “degraded reef” language for citing. The third is removal of that language related to depuration for COL renewal requirements.

These next proposed changes are more related to administering some of these new authorities in the program. The first is adding language to differentiate COLs for harvest from COLs for restoration. We propose to do that in two ways. First off, designating the purpose of a COL right from the onset at the application process, asking the applicant if this is designated for harvest or if this for restoration. And secondly, specifying that no harvest can occur on COLs designated for restoration.

Next, we have here several proposals that are related to that broad authority given to the Commission related to COLs for restoration.

I’ll note before I run through these that these all match the current COL for Harvest Program with the exception of that rental fee. So that application/renewal fee of $200 that matches what’s currently in place for COLs for Harvest, we’re proposing the same for COLs for Restoration.

The location term of 15 years, that’s the same for harvest, again, proposing that for restoration. Acreage maximum of 100 acres per individual COL. Again, same for harvest; we’re proposing that for restoration. We believe that siting application process will be similar across harvest or restoration COLs.

Like I said, this rental fee we’re proposing that be waived; that’s different from the current COL for Harvest Program. The purpose there is taking into account some of those ecosystem services that oysters on the landscape provide. And so, taking that into account.

Next, we propose a cultch placement plan and minimum use criteria related to COLs. The first adds language requiring a placement plan to be submitted during that application process.

For both types of COLs, this would just specify things like the types of cultch materials and planning for placement of those cultch materials, how frequently that kind of thing. This is really just helpful when we look at siting these COLs and determining if a COL with particular activities is appropriate for a given area in the bay system.

Secondly, we propose adding a minimum use criteria specifically for restoration COLs. And this is really just to assure that COLs set aside for restoration are in fact being restored by the applicant. I can get into more details on that, but what we propose that minimum use criteria to look like would be essentially a percentage of that placement plan to be completed within specific time intervals throughout that rental phase.

And then we propose to modify language associated with public hearings for COLs. So, all COLs given their long-time frame are required to have a public hearing associated with them.

We just propose to include language that includes a broader array of public comments and concerns in the stated purpose of the hearing because we are now looking at a broader use of COLs.

Then lastly, this is some of those proposed modernizations to Texas Administrative Code that are fairly independent of the  changes to Parks and Wildlife Code. This just includes modernization of some of the mapping requirements stated in Texas Administrative Code primarily allowing for the use of modern GPS and mapping softwares and that process, modifying marking requirements. This is really just removing marking requirements during the application process and only requiring marking once the application process is complete. And then in addition to new authorities for non-harvest activities including moving oysters from one location to another, emergency sampling to monitor conditions of oysters on these COLs, and any sort of emergency maintenance activities.

With that, I will state our request formally, and that is that staff seeks permission to publish proposed amendments to the Texas Register for public comment.

With that, I’ll take any questions.

CHAIRMAN HILDEBRAND: Thank you. Any questions for Mr. Olsen?

COMMISSIONER DOGGETT: Leslie Doggett, I have a question.

so, I think it would be very meaningful for me, anyway, to understand the overall state of oyster reefs in… off the Texas Gulf Coast. If I use Dr. Campbell’s number of 260 oysters per sack times 223, that gives us 58 million oysters harvested in the 2023‑2024. To put all that in perspective, do you know what the harvest was ten years ago, maybe even 20 years ago?

DR. OLSEN: Are you talking about for the wild harvest?

COMMISSIONER DOGGETT: Yes, wild harvest.

DR. OLSEN: Yes, I can speak to the last couple of years.

Wild harvest on… so I can speak private versus public.

So, we’re talking here about the public reef system and then talking COLs as they currently exist.

COMMISSIONER DOGGETT: Is the 58 million…  Is the 223,000 sacks, is that private and public? It’s both?

DR. OLSEN: That’s both combined.

COMMISSIONER DOGGETT: So total number?

DR. OLSEN: Yes. Kind of what we’ve seen kind of across time over the past several decades, and especially in the past couple of years, is a reduction in the wild harvest. That’s mainly been due to closures that we’ve been instating in some of these areas because we have a fairly low abundance of market oysters.

So, the Department does go out and sample a lot of our public reefs… or all of our public reef areas to determine the catch rates of market oysters, then from there we make a decision to open or close those areas based on certain thresholds of market oysters that’s required to open those areas.

Last several years, we’ve had very few market oysters, broad scale closures of these areas. So overall harvest has been very low in the last couple of years. In addition, I’ll add that this past spring and about two years ago…

COMMISSIONER DOGGETT: So, the closures are a result of degradation of the reef?

DR. OLSEN: Yes, sir. In addition to that, I’ll say that there’s heavy harvest but we’ve also seen heavy rainfall events. For example, this past spring, summer 2020‑2021, we had really heavy flooding in the Coastal Bend. That resulted in very low salinities and that can also result in wide scale oyster mortalities that results in a closure of those areas.

In recent years, anyway, we’ve been seeing reduction in harvest on a lot of those wild reef.

The COLs that exist in Galveston Bay, to note, we’ve seen also seen some reduction in harvests as well in recent years. That largely surrounds that fact that they are subject to the same environmental conditions that other oysters in those bay systems are subject to so heavy rainfall affects it as well and we’ll mortalities on those as well.

COMMISSIONER DOGGETT: So, do you know how many sacks were harvested 10 years ago?

DR. OLSEN: 10 years? Yeah, let’s see, looking at 10 years ago, we’re looking at around 800,000 sacks. It’s variable from year to year as well, and again with openings and closures and rainfall conditions. Yeah. That’s combined. I’m happy to get you those exact data to you as well.

COMMISSIONER DOGGETT: I guess you would say without the restoration it could be sort of catastrophic for us.

DR. OLSEN: Restoration is certainly  a tool… one of our main tools in our toolbox for managing oysters. And I can give some numbers with regard to the amount of restoration we’ve done over the years, about 800 acres of oyster restoration. With cultch placement, about 1,100 acres of oyster restoration with what we call bagless dredge technique, which is essentially taking buried oyster reef and trying to remove that… get that cultch up to the surface to allow for that natural sediment. So, restoration is a major tool.

COMMISSIONER DOGGETT: Once you restore a reef, how long does it take to produce oysters?

DR. OLSEN: We give it about two years. That’s reflected in my colleague Lindsey Savage’s presentation. If there’s really good salinity conditions in a given year you can see the oysters immediately setting and about a year, year and a half to grow to market. But in general because of variable salinity conditions we tend to give it two years just to allow those oysters enough time to reach market size.

COMMISSIONER DOGGETT: Then how long until you need to restore that reef again?

DR. OLSEN:  It really depends on the amount of harvest that that area is hitting. So certainly, wild harvest when that occurs is removing those oysters in that shell from the reef. Now there are programs in place, my colleague, Lindsey Savage, mentioned House Bill 51 program which seeks to return some amount of that cultch to the reef. But it just kind of depends on the area and how much pressure that that’s getting.

COMMISSIONER DOGGETT: So, it’s $120,000 an acre? That’s what we said originally.

DR. OLSEN: Yeah. That’s the average cost.

COMMISSIONER DOGGETT: How many acres do you think are in need of restoration?

DR. OLSEN: It varies from year to year. Again, I don’t have a number per basis, but I would say in general we’re watching Galveston Bay as an area that has a lot of acres in need of restoration. And then as we move down the coast, there’s some less need for them, but still some need in every bay system.

COMMISSIONER DOGGETT: What does that mean?

DR. OLSEN: I don’t have a total acreage for you. It varies from time to time. I’ll mention with a program like the COL program, when we identify for restoration we do quite a bit of sampling on that.

COMMISSIONER DOGGETT: I guess just to understand the scope.

If you had… if money wasn’t an issue‑‑ which of course it is‑‑ is there 500,000 acres that could use restoration or is there 1,000 acres that need restoration?

DR. OLSEN: In Texas, I’ll give the overall acreage of oyster reef ranges we believe it’s somewhere around 75,000 to 85,000 acres total of oyster reef. Some of that is harvestable, some of that is not harvestable. About 50% of that is harvestable. I don’t have an exact number.

COMMISSIONER DOGGETT: 45,000 to 50,000 acres?

DR. OLSEN: 50,000 is harvestable. Not all of that is currently in need of restoration. But that’s all that’s harvestable.

COMMISSIONER DOGGETT: What would you say, half?

DR. OLSEN: Possibly. Possibly.

COMMISSIONER DOGGETT: Okay, great. Thank you for that perspective.

CHAIRMAN HILDEBRAND: Okay. Any other questions? I’ve only got one. Why would someone sign up for a COL to restore?

DR. OLSEN: Yeah. Good question. I think where we’ll see interest in this is coming from a lot of our restoration partners, a lot of our university groups, our conservation organizations.

The value of using the COL process for restoration is guaranteed long‑term protection from harvest. You can currently restore oyster reef outside of this process; you need a GLO lease and an Army Corps permit. But if you want to do that within waters currently open to harvest, we primarily, historically, only come to the Commission with a two‑year closure request like Lindsey just did, but a COL would guarantee a longer-term protection of that from harvest on that restoration site.

CHAIRMAN HILDEBRAND: Would you issue a COL in areas other than Galveston Bay to do this?

DR. OLSEN: Yes. The idea is that we would open it to wherever the need is.

CHAIRMAN HILDEBRAND: So, it should expedite the restoration process versus going through the GLO.

DR. OLSEN: To be clear, you’d still need the GLO and Army Corps authorizations for this COL process. The only difference here is that we would have a longer term… guaranteed longer term closure to harvest.

CHAIRMAN HILDEBRAND: Is the Corps of Engineers an impediment to getting‑‑ that’s too strong– I mean, do they slow the process down quite a bit?

DR. OLSEN: The Army Corps of Engineers coordinates with many of the other federal agencies that have authorizations here, and that process has been very slow.

CHAIRMAN HILDEBRAND: Has been slow. Okay. Great. All right. Thank you, Mr. Olsen. No further questions. I’ll authorize staff to publish the rules in the Texas Register. It’s 10:55. Before… I’m going to take a ten‑minute break. So, at 11:05, let’s all come back. So, grab a cup of coffee, and thank you.

CHAIRMAN HILDEBRAND: Okay. Thank you for the quick break.

Work Session Item Number 10: Chronic Wasting Disease (CWD) Detection and Response Rules, Request Permission to Publish Proposed Changes in the Texas Register.

Mr.  Alan Cain, please make your presentation.

MR. ALAN CAIN: Good morning, Chairman and Commissioners. For the record, I’m Alan Cain, Big Game Program Director in the Wildlife Division.

This morning, I will be presenting proposed changes to rules governing CWD response and management and rules pertaining to deer‑breeder facility standards as well as rules pertaining to CWD management measures with a pathway forward to remove CWD zones.

Since the first detection of CWD in Texas in 2012, the Department has utilized zones to help manage the disease as well as inform hundreds of landowners where CWD is present in Texas.

The core management actions associated with zones are rules for live-animal movement and movement of carcasses into and out of those zones. Mandatory testing of hunter harvested deer has also been required in zones to monitor the disease distribution and prevalence.

Over the last decade, the number of CWD detections in both captive and free‑ranging deer populations has increased, and the Department had continued to add zones, nine containment zones and 26 surveillance zones, to manage CWD. Over this time period, the Department has continued to adapt its CWD management approach, utilizing new tools and CWD testing requirements that improve our ability to detect the disease earlier and reduce the spread of the disease to new areas.

Some of the changes included over this time period are improved testing standards for deer breeding facilities that require 100 percent testing of all mortalities that occur in the pen and 100 percent live animal testing of all breeder deer prior to transfer to another breeder facility or a release site.

Additionally, there has been changes that enhanced testing standards for trace breeding facilities and release sites and the recently adopted statewide carcass disposal rules. These changes and others allow for more effective CWD risk mitigation than in previous years. At the Commission’s direction, the Department has developed rules to move away from CWD zones.

The proposed changes I will present are intended to be that pathway forward to remove those zones.

As we move forward, it is important to emphasize that these proposed rules eliminate the need for staff to present new CWD zone rules to the Commission every time CWD is detected in a new captive breeding facility or in a new free‑ranging deer population.

And along the way, the Department hopes to continue to strengthen the trust between landowners and hunters in the department. We need support from all these groups to be able to manage this disease.

So, in order to move away from CWD zones, certain rules must be implemented to continue mitigate the disease risk. These proposed rules can be thought of as kind of different buckets or categories. That is how I look at them. Those include… those buckets are repealing the zone itself, carcass disposal modifications, requirements for deer breeding facilities and release sites, proximity rules for live-animal movements from areas where CWD is known to exist, enhanced rules for CWD positive breeding facilities, and additional rules for epidemiologically-linked breeder facilities. So, I’ll kind of go through each of these buckets as we move through the proposals.

So, starting with carcass disposal rules, or modifications.

As you may recall, this Commission adopted statewide carcass disposal rules in May. It requires hunter harvest deer in Texas to be disposed of in one of three ways and include disposal in a landfill, so which means you can put those unused parts in your local trash service or dumpster that ultimately ends up in a landfill; or hunters can still take their deer to a locker plant or a processor or a taxidermist, and they have a process and they would be responsible for the disposal in one of those methods; the other method would be burial on a location other than the property of harvest and being able to return those unused parts back to the property of harvest.

Additionally, hunters are also able to debone carcasses at the site of harvest to help leave those potentially infectious parts back where the harvest occurred. And with the archery season and MLD season and then opening weekend of general season this past weekend, that has been happening for about a month here, we have had the opportunity to receive some constructive feedback from hunters and landowners and even some of our own staff on some of the carcass rules. As a result, proposing some modifications and clarifications to these rules.

Those proposed changes include aligning the out-of-state carcass movement restriction rules to match the in‑state carcass disposal rules. The change simplifies rules for all hunters residing in Texas and requires the same disposal options just mentioned regardless of where that carcass came from. In state, out of state, it doesn’t matter. It just has to be disposed of properly. And simplification of the rules is always a goal, and that is what we are attempting to do here.

Additionally, we are proposing to allow deboning of carcasses at a location other than the property of harvest. Again, a simplification of a rule. And that allows for common scenarios that hunters use when processing deer regardless of where that carcass is deboned, proper disposal is required. Next, we propose to clarify that any unused parts retained for future disposal must be contained until disposal occurs. So, in other words, if you are back at the house, we don’t want you putting the ribcage or the spinal cord… or column in the backyard and letting your dog chew on it. It needs to be kept up, so it doesn’t get drug across the countryside there. And if a burial of unused parts is the chosen method of disposal, then the burial must occur immediately and leaving an open pit until the end of season will not be allowed. Lastly, rendering of carcasses as a legal means of disposal will be prohibited.

The next bucket of rules pertains to deer breeder facilities and release site standards.

To further reduce the risk of CWD transmission when animals are transferred to and from breeder facilities, the Department proposes requiring a double fence around all new breeding facilities or facilities that are required to double fence for other reasons as I outline later in this proposal. The additional perimeter fence is a common‑sense practice that eliminates nose‑to‑nose contact between deer in the breeder facility and free‑ranging deer in the pasture. And so, to better visualize this, the diagram on the screen illustrates what that double fence would be. And so, you have the green square, which is considered the ranch there, Ranch “A”, and Ranch “A” has a deer breeder facility denoted in white. And within the permitted breeder facility are deer pens and the working barn in this example. So that perimeter fence, so that black outline of the entire facility would be considered the double fence.

The proposed standards associated with this double fence would require a 7‑foot‑high net wire perimeter fence that is completely surrounds the breeder pens and other facilities that are within that permitted facility. The breeder facility perimeter fence must be at least five feet from any pen or a structure within that permitted facility that could hold deer. No food or water can be in the open area around the pens and working barns. No animals of any kind may be held in the buffer area, so that white area outside of the pens and around the working barn.

However, non‑susceptible species may be handled in the working barn. Next, the buffer area may be used to facilitate movements from pen to pen as long as someone is present and actively engaged in moving deer. We just don’t want somebody letting deer sit in there for 24 hours. You need to be moving them around.

There is no maximum distance between the perimeter fence to the pens or other facilities. That’s intended to allow expansion for the pens in the future and provide for various distance scenarios of existing breeder facilities that are already double‑fenced. Anything within the boundary fence is to be considered part of the permitted deer breeder facility, which means there’s no hunting that can occur in there. No activities that can occur in there other than what’s allowed under the Deer Breeder Permit.

The Department has also encountered several issues with scenarios where two distinct permitted deer breeder facilities share a single working barn as illustrated in the diagram on the slide. It certainly creates concern because of the potential disease exposure through environmental contamination within the shared working barn.

So, in this example on the slide, Facility 2 has a CWD positive deer that is shown in red there, and the working barn was used to work that positive deer along with other deer from Facility 2, and then Facility 1 also uses that working barn. And this would expose deer from Facility 1 to prions that could potentially been shed in that working barn in a situation like this. In this situation, if one facility has been confirmed positive, then both facilities are going to be locked down and placed under a quarantine because of that potential exposure. Essentially, the two facilities will be treated as one facility from an epidemiological perspective.

Because of that scenario, the Department is also proposing amendments to deer breeder facility standards to clarify that all working barns or other facilities must be distinct to an individual permitted deer breeder facility. So, no shared working barns between the two different permitted facilities.

The intent is to prevent both facilities from becoming locked down if CWD is detected in one facility or the other.

Under current rules, two different deer breeding facilities may be fence line adjacent as illustrated on the diagram on the slide. Obviously, Facility 2 in the orange and Facility 1 in green. And this becomes problematic because these are epidemiologically considered one set of pens with potential exposure through nose‑to‑nose contact or shared equipment, as well as environmental contamination.

So, Facility 2, again, has a positive deer in red. And that deer’s fence‑line adjacent to Facility 1. There is no… there is possible exposure between the deer in the two different facilities there through nose‑to‑nose contact.

In a situation like this, both facilities would be locked down because of potential exposure to the positive deer or even to trace deer that may have come into one facility or another.

This is a bad business practice for two distinct permitted breeder facilities to share a common fence line which would facilitate exposure among those facilities.

Therefore, the Department proposes to require distinct permitted breeding facilities on the same property to be separated by a minimum of ten feet. Again, this is to prevent nose-to-nose contact between the facilities and to prevent facilities from becoming locked down because of a trace or a CWD-positive detection in one facility on another.

The Department is also proposing rules that would stipulate the enforcement of visible identification requirements. That is currently outlined in the statute for all breeder deer. Those tagging requirements include a form of electronic identification that must be either a microchip or an RFID 840 button tag, a tattoo for any deer transferred from a facility that it was born in, and an ear tag with a unique identification displayed on the tag. So, this illustration provides these examples. Obviously, you have got the electronic ID up top. You got the microchip or the button tag, the tattoo and the ear tag.

Release breeder deer with visible identification would aid in accelerating the speed in which epidemiological trace scenarios can be cleared by locating and testing those animals if they are available in the pasture. Further, it provides neighboring landowners greater assurances that escaped animals can more easily be identified on their property. An inclusion of visible ID on released deer has been and continues to be a contentious issue among some stakeholders. The Department is continuing to work with stakeholders to build consensus as it pertains to this topic.

Next, the Department is proposing a requirement for new breeder facilities and newly registered release sites following the effective date of this rule, should it be adopted. And that is to have a fence inspection completed by a facility inspector to verify that the breeder facility meets the double-fenced standards that we were talking about and that all new release sites meet fencing standards and requirements that are currently in rule. Those standards include a 7‑foot fence of welded mesh wire or chain link capable of retaining released deer. I will just note right now there is about 65 facility inspectors that are authorized by the Department. We have standards that are established in regulation of who those individuals can be.

The next bucket pertains to proximity rules for live-animal movements.

If CWD zones are removed, the Department must establish rules to manage the movement of live animals within a specified distance of any free‑ranging detection. Currently, deer breeder facilities within Containment Zones are limited to releasing deer on release sites within a Containment Zone as illustrated on the slide.

So again, that red circle is the Containment Zone. The blue rectangle in the top of that red circle is a breeder facility.

This… the yellow arrow signifies the release of deer to a release site within that Containment Zone.

So, over the last year, the Department has received requests to provide provisions to allow deer breeders within a Containment Zone to move deer to a release site or breeder facility outside of that containment zone. So statewide movement outside of those containment zones is what we are talking about.

In order to facilitate this request, in the absence of zones, the Department must ensure standards are in place to mitigate the risk of moving deer from areas where CWD is known to occur to other areas where it is not known to occur or has not been detected. Currently, the size of containment zone boundaries are based on the average dispersal distance of yearling bucks which for white-tailed deer is about five miles, and for mule deer it is about 25 miles. Sometimes boundaries in containment zones are adjusted to follow the nearest road or some definable feature to make it easier for hunters to understand that zone boundary.

So, the next few slides that will describe… I will use to describe the proposed rules for deer  breeders to move deer within or beyond that distance of five miles or 25 miles from a positive free‑ranging detection of a white-tailed deer or a susceptible species, or 25 miles of a free-range mule deer detection. The proximity rules I’ll discuss should be considered in the context of these specific distances that I have on the slide. And just for scale, you see the blue line there. That represents a 25‑mile radius from the positive, and the pink line represents a five‑mile radius on either side of that positive detection denoted by the yellow cross there.

So, for a deer breeder facility within the five or 25 miles of a free‑ranging detection, that facility can release deer to an adjacent release site or any release site authorized to receive deer within that five or 25‑mile distance of the free‑range detection. No additional requirements outside of the current rules governing movement are necessary. So, it is kind of business as usual here. The diagram illustrates where deer in the breeder facility on Ranch “A” can be released. As you can see, you can either release to your adjacent release site or you can send it to another release site within that five‑mile or 25‑mile range depending on the type of free‑range detection.

In the next scenario, assuming a deer breeder facility is located within that specified proximity distance of a free‑range detection and they’re movement qualified as at the time of detection, that facility may transfer deer outside of the proximity area to any other deer breeder facility or release site in the state if that deer breeder facility has been double fenced for at least one year prior to the free‑range detection and those double fence standards are as I described earlier, under the breeder facility standards we just went over–  and that facility has completed one whole‑herd live-animal test which may be initiated immediately upon detection. Because that double fence has already been in place for a year or more, preventing that nose‑to‑nose contact.

The proposal as published would also have required the facility to wait one year after the whole‑herd test to move deer, but based on feedback from stakeholder groups and further assessments of this scenario, the Department is removing that requirement from this proposal.

Likewise, for facilities that have been double‑fenced for less than one year prior to detection and would like to be qualified to move deer outside of that specified proximity distance to a free‑range detection, that facility must wait one year from the date of the completion of the double fence to conduct a whole‑herd ante-mortem test and then wait another year after completing the whole-herd test to move deer and be movement qualified at the time deer are to be moved. And just as a reminder, they would have to test each individual deer to be transferred as required under the current rules. You have to have a live animal test to move deer once you are movement‑qualified.

Noting there may be some special circumstances for a very few deer breeders, currently in the containment zone that are already double‑fenced and already movement‑qualified, the Department is proposing to allow breeder facilities that are in containment zones at the time this rule becomes effective, if adopted, to transfer deer statewide. The proposed amendment would be applicable to very few deer breeders. Currently, there are only three deer breeders with the containment zones, and only two of those had deer in the facility. In these scenarios, these facilities are double‑fenced, have significant testing history in their facilities and on the adjacent release sites, and there has been significant testing in the surrounding CWD zones.

The Department had initially proposed to issue Deer Breeder Permits to applicants within the proximity area, as required by statute, but permit that facility to hold zero deer. However, with some additional feedback and assessment, the Department will issue a deer breeder permit with authorization to hold deer contingent upon meeting certain requirements and standards and remove the language that would permit the facility for zero deer. The Department would need to work on those additional standards before this goes to the Register.

Next, deer that escape from a breeder facility within that five or 25‑mile free‑range detection shall not be allowed to recapture those escaped deer unless it is authorized by the Department or through a herd plan. This is intended to prevent possible exposed escaped breeder deer from being returned back to a facility.

The Department also proposes to prohibit the issuance of Deer Management Permits, or DMP permits, on epi‑linked release sites anywhere in the state. The current proposal also included a provision to prohibit DMP permit issuance within the proximity of a CWD-positive free‑range detection. However, after feedback from the White-Tailed Deer Advisory Committee and further review, the Department intends to strike this portion of the proposal and allow DMPs to be issued but with some requirements to mitigate risk. Some of these additional requirements may include CWD testing on that property or visible ID for DMP deer. Staff intends to develop these additional requirements and vent those through key advisory committees prior to sending the proposal to the Texas Register.

The next bucket pertains to proposals regarding CWD positive deer-breeding facilities.

Before I move on to the actual part of the proposals, I want to take a few minutes to walk through the diagram. I think this will be helpful, and it illustrates some common examples and terminologies used to describe facilities or release sites connected to a CWD‑positive facility. So, I will refer to some of these terms and examples in the next few slides when we talk about the rule proposals.

So, starting in the upper left with facility 1. This is referred to as a trace-in breeder facility because that facility sent deer to a positive facility within five years prior to detection in that positive facility, which is Facility 2. The deer in blue on the diagram represent the trace‑in deer that were sent to Facility 2 from Facility 1. The trace‑in deer could be the source of CWD introduction in Facility 2 and are of interest from an epidemiological investigation perspective.

Facility 2 is a positive facility with the positive deer denoted in red. That positive facility may have sent deer to another deer breeder facility or release site within the five years prior to detection in that positive facility. So those facilities that received those deer from the positive facilities are referred to as trace‑out breeder facilities which is Facility 3 or Ranch “A” which would be a trace‑out release site. The yellow deer are trace‑out deer and are deer from the positive facility transferred to these other facilities, Facility 3, through the release site and possibly exposed to CWD while in that positive facility.

In some instances, these trace-out deer sent to release sites are not available for testing for various reasons, whether they were harvested, just died in the pasture, or just unable to be found out there.

In these scenarios, traces that we talk about they are often referred to as trace‑in or trace‑out or epidemiologically linked facilities or release site or epi‑linked. So, that is just common terminology that we use.

So, moving on to the proposal. Hopefully, these diagrams help explain what we are going to be talking about here in a minute. The next‑‑ I will review a few additional proposed rules intended to mitigate‑‑ further mitigate risk associated with positive breeding facilities.

The first is a requirement to euthanize and postmortem test all trace-in deer in a positive facility within 7 days of confirmation. This will be a tremendous help in freeing up trace-in breeder facilities that would otherwise become not movement qualified because the trace deer they sent to the positive facility have not been removed and tested. In some instances, these trace‑in deer breeder facilities remain not movement qualified for months because the trace deer remain alive in that positive facility for whatever reason. It is not until that positive facility euthanizes those trace-in deer and not detected test results are returned before that trace-in facility can be returned to Movement Qualified status.

Second, in order to expedite an epi‑review of a positive facility, the Department proposes that positive facility submit a pen‑by‑pen inventory within 14 days of confirmation, including the location of where that positive deer is in the pen.

Third, movement between pens in the facility would be prohibited unless otherwise authorized by the Department. Again, this would help prevent exposure and potential spread to other pens or other deer in that facility.

And lastly, the Department proposes that positive facilities must sign a herd plan within six months of detection or agree to depopulation. The intent behind the proposal is to expedite CWD mitigation measures through a herd plan. Those facilities that choose an option that does not include depopulation would be required to double fence their facility by the time they satisfactorily complete their plan and remove from the quarantine.

The last bucket of proposed items pertains to epi‑linked deer‑breeder facilities. And these are trace‑in or trace‑out facilities as I was referring to in those earlier diagrams.

So, the next proposal would include several changes for trace‑out breeder facilities in which some or all the trace deer are not available for testing. These trace‑out facilities are currently called Category B facilities, and that’s when not all trace deer available. The proposal would return the trace‑out breeder facility back to Movement Qualified status if the following standards are met.

One: At least one trace deer has to be unavailable for testing and then any available trace deer in the trace‑out breeding facility has to be postmortem tested and return a not‑detected result.

Second: The trace deer must have been received in that 3- to 5‑year trace‑back period prior to the detection in the positive facility. The trace deer must have had at least one antemortem or live animal test within the last five years. The trace out facility must be double‑fenced. And the trace-out facility has been compliant with all rules for the last three years prior to becoming designated as a trace‑out facility.

The Department’s also been engaged in numerous discussions with key stakeholder groups and their leadership to develop the following proposal to curtail trace designations for breeder facilities in that zero- to three‑year trace period. The proposal would require the following conditions be met in order to remove the trace designation.

First, the trace‑out breeder facility must be double‑fenced prior to designation as a trace. So, that is an incentive to double fence. The facility must achieve 25 percent annual testing for at least two years prior to designation to a trace using a combination of postmortem and antemortem tests. The breeder facility must be in compliance with the deer permit requirements and regulations. And the trace‑in deer in that facility must have 20 months residency in the trace‑out facility and have an antemortem rectal test that occurs after that residency requirement is met. This portion of the proposal was not able to be included in the proposed rules package that has been published online, and it hadn’t been vetted with the advisory committees prior to this meeting. Therefore, the Department will seek input and vet this proportion of the proposal with the CWD Taskforce and other key advisory committees prior to the January meeting to receive feedback. And also let the Commission know that the Department is also assessing options to curtail trace designations on release sites in a timely manner and with reasonable and practical standards. And so, we will continue to flesh that out moving forward.

So, the Department has had an opportunity to receive feedback and comment from the CWD Task Force, the White-Tailed Deer Advisory Committee and the Private Lands Advisory Committee.

And the next several slides are a summary of that feedback.

So, the CWD Task Force has been supportive of the proposed changes for the removal of the zones and several other things.

I do want to acknowledge that Vice‑Chairman Bell and Commissioner Galo were in attendance at the CWD Task Force, and we appreciate your participation and support in that meeting. So, thank you.

So, again, the Task Force was supportive of the number of items in this proposal package, including the removal of zones, proposal pertaining to the carcass disposal rules, double‑fencing of new deer‑breeder facilities, separation of distinct permitted breeder facilities and no shared working barns, and the requirements for CWD‑positive breeder facilities that we talked about. And there were varying perspectives in support and opposition of the proximity rule including concerns over both the whole herd test requirement for facilities that had been double fenced greater than one year and having to wait a year after that whole herd test to be able to move deer. However, as I noted earlier, the Department is removing this requirement after additional feedback. Some members recommended to be able to move immediately. And others were supportive of the one‑year wait period after the initial whole‑herd test. There was also a disagreement on the visible ID requirement. Some supported the requirement as a means to identify trace deer in the pasture, or in those release sites and the ability for the neighboring landowners to identify trace deer should it escape that release site. And then they have an option to be able to identify that deer and decide what they want to do in that situation. Others oppose the visible ID requirement noting that the ID requirement should be addressed by the Legislature and it should be the choice of release site owners whether the visible ID is retained or not. And noting that breeder deer have been tested prior to release and many have already required– or not required, but many deer breeders already retain tags in deer they send to release sites and other places as a standard practice so suggested the change was not necessary.

The White-Tailed Deer Advisory Committee was also supportive of the same things. Removal of the CWD zones, the carcass disposals, the double‑fencing requirements, the separation of permitted deer breeder facilities, no shared working barns, and the standards for positive facilities. I also want to note that the committee, the White-Tailed Deer Advisory Committee , recommended that breeder pens maximum size of 100 acres be reduced to something much smaller which should help aid in the mortalities in those pens and accounting of deer inventories in those facilities. Although this is a very good recommendation, it would require a statutory change by the Legislature to reduce the pen size. There is mixed support, or opposition, for several of the proposed changes. One of those, again, was visible ID for all breeder deer, including upon release. Some members of the committee supported the visible ID requirement. Again, noting the importance of visible ID to aid in the ability to ID removed traced deer on a release site. Additionally, visible ID provides landowners and hunters the ability to ID breeder deer that may have escaped the release site providing them the opportunity to remove that deer if possible. Others were not supportive of the visible ID, noting release site owners should have a choice whether tags are retained and retaining ID is a standard practice for many deer breeders that sell deer to release sites.

So, the change is not necessary.

In current policy that we are operating under now, it has been to only to require the tattoo and one form of the electronic identification upon release. There was some discussion and concerns regarding the retention rates of dangle tags and possibly those tags being dislodged after release and that a better option might be a minimum standard of the RFID button tag as a visible ID. Additionally, there were discussions and suggestions that a tattoo be required in the fawns by March 31, following their birth year just to enhance the tattoo quality and durability. However, that tag size or requirements for the RFID button tag or the date that a tattoo would need to be in the fawn’s ear would be statutory changes, again, that have to be handled by the Legislature. And I will note there is some research that’s been conducted. It shows retention rates of the ear tags are really high, upwards of 90‑plus percent. So I just wanted to share that as well. There is also disagreement by some for the release site fence inspection requirements. Several noted the concerns for additional cost burdens on release site landowners, concerns about the number of Department‑approved facility inspectors out there, and a possible bottleneck that could occur to meet inspection demands in a timely manner.

Additionally, some noted that the TWIMS system already requires an acknowledgment of the fence requirements by release site owners when the register a new release site in the TWIMS system.

And others noted the need for the inspection to address fraudulent scenarios where a landowner may create a fictitious release site or a registered release site that is not completely fenced and not compliant with the current requirements.

There is also some opposition to the proximity rule requirements for breeder facilities that have been fenced greater than one year. And again, having to wait a year after a whole‑herd test to move deer. As noted previously, the Department intends to remove that one‑year waiting period to be able to move deer for those facilities that have been fenced greater than one year. A few others suggested no whole‑herd test or a custom epi review be used to allow for flexibility to consider other factors such as past testing history in that facility or surrounding release sites… or testing in surrounding release sites in those free-ranging populations.

Lastly, there was a recommendation from some on the committee to remove the requirements prohibiting DMP within the proximity distance and within that proximity distance but with some certain requirements in place to address that. And as I noted earlier, we were proposing to allow that change to allow DMP within that five- or 25‑mile proximity distance.

And the last group we talked to is the Private Lands Advisory Committee. And they provided some comments on the proposal generally supporting the removal of CWD zones, the carcass disposal rules; again, the positive breeding facility standards and visible ID. However, there were some concerns by a few individuals about the fencing inspection requirements and additional financial burden on deer breeders and landowners releasing deer. Additionally, suggestions were made to require fence inspections of existing release sites currently registered with the Department that will release deer in the future.

Also require — suggesting a requirement that the Department disclose the location of CWD detections and also the property boundaries of trace release sites not in compliance with herd plan requirements. And we had a suggestion to postpone the rules pertaining to curtailing traces from breeder facilities in that zero- to three‑year period considering the increased number of detections in the past two years. The committee did ask TPWD to come back, or the Department staff, to come back to that committee after the Commission meeting to further discuss commission feedback and any recommendations to staff so that the Private Lands Advisory Committee can provide additional comment prior to the January meeting.

So, these next two slides are not rule changes that are being proposed, but I did want to elaborate briefly on the Department’s CWD outreach and surveillance efforts moving forward, especially in light of the possible removal of CWD zones.

So I hear comments occasionally that the Department is throwing in the towel with removal of zones or some of these changes.

And I just want to state emphatically, that’s not the case.

We are not throwing in the towel.

The Department will continue to inform hunters and landowners of where CWD has been detected, utilizing technology such as the Texas Hunt & Fish app which you see a screenshot of that there on the slide. And where CWD detection locations can be displayed and color‑coded by the type of detection, whether that was in a captive facility or free‑range positive…  you know, when that positive occurred. Other information: If it is a captive facility, has it been depopulated? We want to empower landowners and hunters and deer breeders with the best management practices so they can make informed decisions about how they may want to help manage the disease on their properties.

It must be clear that hunters and landowners will play a key role in helping manage this disease. In fact, one of the best things that we can do is to continue to encourage and support deer harvest and deer hunting. As I often say, good deer management is good CWD management. If you manage your deer populations and keep your numbers in check with your habitat, that helps to reduce or maintain prevalence rates of CWDs out there on the landscape, it removes potential hosts from the landscape, and good habitat management helps to improve fawn recruitment rates which can also help to buffer against impacts of CWD on deer populations.

So, it’s critical we continue to strengthen that trust between landowners, hunters and the department. This proposal and the pathway forward will help to do that by removing disincentives for sampling statewide because there are no repercussions for testing, i.e., no zones.

Lastly, I wanted to touch on surveillance efforts moving forward. The Department does intend to maintain or expand opportunities and ways hunters and landowners can submit CWD samples. Some of these options would include check stations in key locations, drop boxes, so a freezer where you can drop a head off, or a do‑it‑yourself, mail-in kit which we are testing in the Panhandle this year. So, hunters collect a sample, they mail it in. We can take that information and sample and send it on to the lab. And lastly, they can coordinate with a biologist or CWD seasonal to get their samples collected.

Additionally, it’s critical that the Department continue to inform hunters and landowners about our sampling goals throughout the state. How can we expect hunters and landowners to help us and be aware of our sampling goals and needs if we don’t let them know what those goals are? Whether that’s at a county level, a deer management unit level, or a specific area of interest.

To address that, we hope to be able to utilize a public-facing CWD dashboard similar to what you see on the slide to let folks not only know about our CWD sampling goals and efforts in those particular areas, but also real‑time what samplings have occurred throughout the deer season. That way, a hunter or landowner that’s viewing this map throughout the season can say, “Oh, I see there’s only ten samples in Gillespie County, they need 20.

So I’m going to help them reach their goal by providing samples.” So, we need to be able to continue to do that.

And finally, we will also continue to investigate the possibility of using alternative sampling methods such as RT-QuIC that this Commission has heard about multiple times over the last year or two.

So, with that, staff requests this item be placed in the Texas Register for public comment. And I’ll be glad to answer questions.

CHAIRMAN HILDEBRAND: Thank you, Alan. Any questions by the Commissioners?

COMMISSIONER ABELL: Commissioner Abell. I have just a couple of small ones. On the double fencing requirement, if I want to be a new breeder, if I’m on a property that is already high‑fenced, does that then have to be double fenced, or is the perimeter fencing considered the double fence?

MR. CAIN: You need to be double‑fenced around that facility.

In your example, if I have a ranch and it is under high fence, and I have got deer running around in the free range out there and I hunt that, then that perimeter boundary fence on the property doesn’t count. Because, like I said in the package, everything within the perimeter fence, that double fence, is considered part of that deer breeding facility. So, at that point your whole ranch would be the deer breeding facility. You couldn’t hunt or do anything there other than what is permitted. The intent is to double‑fence to prevent nose‑to‑nose contact with everything outside of that.

COMMISSIONER ABELL: Got it. On my other question, on the visible ear tags, are there any guidelines on size — like a minimum size of the tag?

MR. CAIN: Yeah, it’s in statute, and I don’t recall off the top of my head what they are. And the lettering has to have a certain size. I think it is, whatever, 5/16th or half an inch tall. No more than 5/16th-inch gap between the letters and it has to be on a background that’s light enough, that there is a contrast between the…

COMMISSIONER ABELL: Thank you. Great work.

MR. CAIN: Thank you.

COMMISSIONER GALO: Commissioner Galo, I have a question.

So, there was an addition where the trace deer must have 20 months residency in a trace‑out facility. I don’t know what slide it was. And you did say that it has not been vetted with the CWD advisory committee, correct? But you are going to go back and vet that with them?

MR. CAIN: Yes. This was a late addition. Again, through some last‑minute discussions. We are going back to the advisory committees to present this and receive feedback.

COMMISSIONER GALO: Okay, well, I don’t know if this question might be for Dr. Reed, but do you feel like this change is scientifically defensible?

DR. J. HUNTER REED: Good morning. For the records, Dr. J Hunter Reed.

So, in terms of this trace‑out requirement, whether or not it is supported by science. So, under the strategy, I think it would reduce the risk of those animals being infected and being released, but it would not eliminate all of the risk. I still think that there would be a more-than-small likelihood that some animals may be released out of a category of these facilities and still be infected.

COMMISSIONER GALO: When you say, “More than slight,” like, what percentage?

DR. REED: So, looking at the literature, if you are talking about an animal with Codon 96 GG– there’s GG, GS and SS– that has the best research. GG, you would have the highest likelihood to detect at 20 months with a rectal test. It is more concerning when you get to animals that are GS or SS. Those animals with those genome types may not be detectable at that point.

The industry is moving in a direction that is looking at those genome‑types more. They are more valuable. They are also less susceptible to CWD. So, there are some benefits to that.

But it does reduce the likelihood of being able to detect the disease in those animals.

COMMISSIONER GALO: I hate to put you in the hot spot but what would be… better than 20 months, I guess?

DR. REED: Yeah. So...

COMMISSIONER GALO: In your opinion. Based on science.

DR. REED: The best way to not be in this situation and to avoid this situation altogether is if you have a deer on a release site and it has a tag in its ear, you submit a test. That animal, if it ends up being a trace animal and it were submitted for testing, we could completely avoid that situation in a lot of these cases. If you are just looking at bucks, I would say about 40 percent of these bucks are of shooter‑buck age. They might be harvested that season. That is a very easy and probably highly recoverable subset of animals that we could really close the gap on these Category “B” type of situations.

If we are moving forward with the rule package, zero to three years with some of these elements, I guess I would try to recommend trying to lengthen the residency time from 20 months to a minimum of 24 months. And also, tonsil testing would be a much more sensitive technique for being able to detect the disease, antemortem testing wise.

COMMISSIONER GALO: Thank you, thank you. Alan, and I had one more question. I think that it was and I might be wrong, on slide 19 there was a removal of some provisions that also I don’t think were vetted by the CWD advisory committee.

MR. CAIN: Slide 19?

COMMISSIONER GALO: What is 19? Maybe it wasn’t 19. It is so hard since I can’t go back...

MR. CAIN: There was a couple of items that haven’t been vetted.

You know, just recent additions. We will continue to move forward and vet those through the advisory committees.

COMMISSIONER GALO: Okay.

MR. CAIN: And I don’t recall which one it was other than what the Category “B” stuff that Dr. Reed was talking about.

COMMISSIONER GALO: Yeah. I know that in the proximity proposal, under Deer Management Permits, will not be authorized‑… i think one of them that wasn’t vetted was a property wholly located within five or 25 miles of free‑range type detection. I don’t think that was vetted. But I didn’t take a picture of the other slide. I can’t get back to it so I don’t remember. But I think you probably will figure it out.

MR. CAIN: Yeah. We intend to, you know…  the items that are recent additions that we haven’t fully vetted, we intend to vet those before this would go to the Register and receive feedback.

COMMISSIONER GALO: Okay. Thank you.

CHAIRMAN HILDEBRAND: Any other questions?

VICE-CHAIRMAN BELL: This is Commissioner Bell. I had a comment.

CHAIRMAN HILDEBRAND: Yes, sir.

VICE-CHAIRMAN BELL: You know, just to have the opportunity to kind of you say more closely observe everyone and their interaction in this. So first, I would like to thank everybody that was involved in all the meetings, all the discussions.

You know, I don’t know that we are going to have, I’ll say, a 100 percent perfect solution. But what we have here in this package, at least for opening discussion purposes, because these aren’t the rules. These are the first sets for discussion and consideration. Some may go through exactly as it is. Some will have some adjustments and some tweaks. It is a good place to start for consideration. And I do know that all of those stakeholder groups were actively engaged, and we appreciate that. So, if we can be successful here, it will also help us avoid, I will say, constantly being in emergency response mode.

MR. CAIN: Right.

VICE-CHAIRMAN BELL: So that this becomes more of a regular management practice for us. And I think that’s a positive piece as well. And these rules will allow everyone to better understand the — our long‑term strategy.

It is an evolution of what we have learned over the past 12 years. So, I think that’s a positive. And we just need to… it is something we are doing in real‑time, so we just have to continue to observe and get better. And, you know, a lot of this I think will be successful. We may have a few hiccups. If we have a hiccup here or there, we will need to make an adjustment. So, we just need to stay conscious, but I think landowners would appreciate what’s going on.

Some of the items here are items that had been sticking points for a long time, that we have now had the opportunity to move forward on and at least have open discussion and consideration.

And everybody is willing to participate and talk about it. So, I would say good job to you, Dr. Hunter,… I mean Dr. Reed, I’m sorry. Dr. Reed. You know, your name kind of...  Your first and last name is almost like one word now, right? Thanks to all the folks over there and just we appreciate the effort.

CHAIRMAN HILDEBRAND: Anyone else?

COMMISSIONER GALO: Commissioner Galo. I do want to echo Vice‑Chairman’s comments. I did see a real effort by TWA and TDA to work together on this. You know, it’s been a long process and there has been a lot of work put into it. And I also want to thank you, Alan, and staff and everyone that has put a lot of hours into this. I really appreciate everybody trying to see each other’s points of views and each other’s concerns. That is all. Thank you.

CHAIRMAN HILDEBRAND: Anyone else? Everybody good? Okay.

Good. Well, I’ll add on…  Alan, thanks, to the staff, advisory committees, all our stakeholders, for all the hard work, the proposed package. I especially want to recognize Texas Deer Association, Jody  Phillips, and Texas Wildlife Association, Jonathan Letz, for their dedication in the process. They have been really fantastic. The collaborative nature as to which those two associations have worked is really wonderful. I can’t tell you how much I appreciate that.

I’m grateful for the commitment of time, effort in developing a clear, flexible, and practical regulation regarding the Category “B” trace exemption as outlined by Alan. The approach will not only enable us to effectively monitor and detect the disease but create a straightforward pathway for facilities to stay movement qualified provided they comply with the rule. And that’s the key here is that we want good actors. We don’t want to prevent people from the deer breeding industry. It is approved by our Legislature, and we need to appropriately regulate it with good, practical, pragmatic rules. And I think from my perspective this is the most comprehensive set of rules package that has come out really since the beginning of the disease.

And I don’t…  it is not perfect. But boy, it is the, I believe, the 80 to 90 percent answer in terms of CWD and the prevention of the growth of it. So with that, once again, thank everyone for their involvement in this. We still have a ways to go before we get to an official rules package. But let’s move forward on it and keep us updated as we progress.

MR. CAIN: Thank you.

CHAIRMAN HILDEBRAND: And thank you for your involvement, Alan.

MR. CAIN: Thank you.

MR. CAIN: And thank you, Dr. Hunter. Well done. Thank you.

CHAIRMAN HILDEBRAND:  Okay. With that, Work Session Item Number 11: Permits to Possess or Sell Nongame Fish Taken from Public Fresh Water, Changes to List of Affected Species and Other Changes, Request Permission to Publish Proposed Changes in the Texas Register.

DR. YOSKOWITZ: Chairman? Chairman? David Yoskowitz, here. Yes, if I could just…

CHAIRMAN HILDEBRAND:  Oh, I’m sorry. If there are no further questions. This is relative to Work Session Item Number 10.

If there’s no further questions, I will authorize staff to publish the rules in the Texas Register. Got it.

DR. YOSKOWITZ: Thank you, sir.

CHAIRMAN HILDEBRAND:  My apologies. Work Session Item 11.

Mr.  Michael Tennant.

MR. MICHAEL TENNANT: Good afternoon, Chairman, Commissioners.

For the record, my name is Michael Tennant, and I’m the Regulations and Policy Coordinator in the Inland Fisheries Division.

Today, I will be presenting proposed changes to the rules governing permits to possess or sell nongame fish from public fresh waters.

To give a quick overview of the proposed changes I’ll discuss today, these include adding Silver Carp and Suckermouth Armored Catfishes to the list of species for which a permit may be issued for commercial harvest and the removal of Freshwater Drum, Minnows, Rio Grande Cichlid to disallow commercial harvest. The proposed changes also include non‑substantive housekeeping changes to standardized terminology.

Silver Carp is native to eastern Asia and were introduced to private fish farms and wastewater treatment facilities in the United States during the 1970s and 1980s as a biological control agent to reduce algae growth and improve water quality conditions in ponds.

By 1980, they had escaped into the Mississippi River system during flood events and subsequently spread rapidly throughout the Mississippi River drainage and beyond. They have become established and potentially problematic in more than ten states, including Texas, where they compete with native species and pose hazards to boaters because they weigh up to 60 pounds and can leap out of the water when startled such as by boat noise, sometimes striking boaters. Silver Carp populations occur in the Red River and tributaries downstream of the Lake Texoma Dam but are not yet highly abundant. There are U.S. and international markets for wild‑caught Silver Carp and regional efforts are underway to incentivize harvest. The proposed rule change would add Silver Carp to the list of fish for which the Department may issue permits authorizing take from public fresh waters for commercial purposes to encourage removal.

Suckermouth Armored Catfishes are native to Central and South America, and multiple species are imported to the U.S. via the aquarium trade to control algae. Aquarists have been known to dump the contents of fish tanks for various reasons which has believed to have resulted in the introduction of several species to Texas waters where high abundance has been documented in some locations.

Suckermouth Armored Catfishes compete with native fish, consume the eggs of other fishes through their feeding behavior, and may cause serious disruptions in food webs and native ecosystems.

They are especially problematic in spring and influence river systems such as those found in Central Texas. They are also widespread in the Houston and South Texas regions where warmer waters allow for over‑winter survival. Additionally, their burrowing behavior causes destabilization and erosion in river banks and earthen dams. There has been commercial interest in the species from pet food producers. The proposed rule change would add Suckermouth Armored Catfishes to the list of fish for which the Department may issue permits authorizing take from public fresh waters for commercial purposes to encourage removal.

Freshwater Drum is native to Texas and is recreationally and ecologically important. The species serves as a reproductive host for numerous species of native freshwater mussels, many of which are threatened, endangered, or recognized as species in need of conservation intervention. The Department has determined that continued commercial harvest of Freshwater Drum is inconsistent with conservation and recovery goals for imperiled freshwater mussels. The proposed rule change would remove Freshwater Drum from the list of commercially harvested species and disallow commercial harvest.

Ten permittees reported harvest of Freshwater Drum between 2014 and 2023 with total sales of $5,911. The permittee reporting the highest sales over the ten-year period reported total sales of $1,800. 12 persons are permitted to commercially harvest Freshwater Drum in 2024.

The Department has determined that seven of 11 minnow genre currently authorized for commercial harvest include species that are threatened, endangered or species of greatest conservation need. 37 imperiled species in total.

Currently, the Department, by special permit conditions, restrict minnow harvest where imperiled minnow species concerns have been identified. Minnows serve critical roles in healthy aquatic ecosystems forming a prey base in the food web, for example. Today, bait minnows are supplied by the aquaculture industry rather than from wild harvest. The Department believes it is prudent to remove minnows from the list of commercially harvestable fish to align with conservation goals and prevent additional state or federal listings as threatened or endangered species.

One permittee reported harvest of minnows between 2014 and 2023 with total sales of $100. No commercial harvest has been reported since 2017. Eight persons are permitted to commercially harvest minnows in 2024.

The Rio Grande Cichlid is native to lower reaches of the Rio Grande and is the only indigenous cichlid native to the United States. Populations have become established outside the native range in river (inaudible) areas of Central Texas’s Edwards Plateau, including the San Marcos Guadalupe, San Antonio and Colorado Rivers.

It has become increasingly popular as a sport fish, particularly among fly‑fishers. The Department believes that removing Rio Grande Cichlid from the list of commercially harvestable fish aligns with recreational fisheries management goals especially for Central Texas creeks and rivers, where sport‑fishing guides offer trips targeting the species.

Two permittees reported harvests of Rio Grande Cichlid between 2014 and 2023 with total sales of $423. No commercial harvest has been reported since 2020. Nine persons are permitted to commercially harvest Rio Grande Cichlid in 2024.

To summarize the proposed changes, staff recommend adding Silver Carp and Suckermouth Armored Catfishes to the list of species for which a permit may be issued for commercial harvest and removal of Freshwater Drum, Minnows, and Rio Grande Cichlid to disallow commercial harvest.

Staff seeks permission to publish proposed amendments to the Texas Register for public comment.

That concludes my presentation, and I would be happy to take any questions.

CHAIRMAN HILDEBRAND:  Great. Thank you, Mr.  Tennant. Any questions? If not, I’ll authorize staff to publish the rules in the Texas Register. Thank you very much.

Work Session Item Number 12: 2025-2026 Statewide Recreational and Commercial Fishing Proclamation Preview.

Mr.  Brian Bartram, please make your presentation.

MR. BRIAN BARTRAM: Good afternoon, Mr. Chairman and Commissioners. For the record, my name is Brian Bartram with Coastal Fisheries, and I will be presenting the Statewide Recreational and Commercial Fishing Proclamation Preview for your consideration.

This is just a preview to apprise you of what we are thinking, and we will be coming back to you with a formal request in January.

There are no proposals for Inland Fisheries’ regulations.

We will jump right into proposals for Coastal Fisheries of which there is only one. Staff are proposing to change the commercial minimum length limit in Texas state waters for Greater Amberjack from 34-inches total length to 40-inches total length. Currently, the minimum length in federal waters is 36-inches fork length. 40-inches total length is roughly the equivalent of 36-inches fork length.

So, we’ve chosen to maintain the use of total length for consistency of fish measurement. And just to define the difference between the two measurements. The total length is measured from the tip of the snout to the tip of the tail. Whereas fork length is measured from the tip of the snout to the fork of the tail as you can see there on the graphic.

So, the purpose of this change is to match the size regulations in federal waters as this promotes ease of enforcement and should also promote compliance amongst participants in the commercial fishery. Length limits that closely match between state and federal waters should also reduce confusion.

Just a quick rundown of the process. We will present our formal request in January, and then we will seek adoption at the March meeting. With the approval of the Commission, the change would take effect September 1st of 2025.

Thank you for your time, and I would like to welcome any questions from the Commission.

COMMISSIONER PATTON: Patton, question. If we really want to avoid confusion, what was the… should we consider looking at fork length rather than total length so that we would be consistent with the federal regs?

MR. BARTRAM: Well, the issue there is that the vast majority of our regulations on our other fish species, those harvest regulations are set to total length. So, it might result in confusion amongst recreational anglers.

COMMISSIONER PATTON: Okay.

CHAIRMAN HILDEBRAND: Any other questions? Seems pretty straightforward. Is this the only…  in the state of Texas, everything is in total length, correct?

MR. BARTRAM: Yes.

CHAIRMAN HILDEBRAND: We don’t use anything fork length?

MR. BARTRAM: Not to my knowledge, no.

CHAIRMAN HILDEBRAND: And do the feds use all fork length?

MR. BARTRAM: A lot of fork lengths, yes.

CHAIRMAN HILDEBRAND: They do. I wonder what the origin of that is?

MR. BARTRAM: There can be variability in the end of the tail.

CHAIRMAN HILDEBRAND: Okay, all right. Great. Sounds pretty straightforward. All right. Thank you very much.

MR. BARTRAM: Thank you.

CHAIRMAN HILDEBRAND: Work Session Item Number 13: 2025-2026 Statewide Hunting and Migratory Game Bird Proclamation Preview.

Mr. Kevin Kraai and Mr. Gray, please make your presentation, please.

MR. KEVIN KRAAI: Thank you. Good morning, actually, close to afternoon. Chairman, Commissioners, for the record, my name is Kevin Kraai. I’m the Waterfowl Program Leader for Texas Parks and Wildlife.

I’m here to provide a quick preview of the potential proposals we anticipate for the ‘25‑’26 hunting season.

Also, just a reminder that our Migratory Game Bird Technical Committee and Advisory Committees will be meeting this December to develop full staff proposals, and we will bring those forth to you this January. I also wanted to remind you that when establishing seasons for migratory game birds in Texas, — here in Texas, we are required to stay within Federal Frameworks established by the U.S. Fish and Wildlife Service.

There are two changes to those Federal Frameworks that will impact our ‘25-’26 migratory game bird season that I will review on the following slides. Oh, yeah. There we go. Aside from those two changes, the season lengths and bag limits for all other migratory game bird species will remain the same.

The two framework changes that I was referencing are inclusive to the early teal season length and the bag limit for Northern Pintails.

The 2024 Waterfowl Breeding Population and Habitat Survey resulted in a blue-winged teal estimate of 4.55 million birds which falls below the established 4.7 million bird threshold to have a 16‑day season, as indicated by the red bar on the graph displayed. Thus, in the ‘25‑’26 season, we will be restricted to a nine‑day early teal season.

The other change that we are anticipating for next year has to do with the pintail bag limit. The 13‑year‑old national harvest management strategy for pintails was recently updated and modernized. The new model uses harvest data and predictions about fall migration to calculate the annual harvestable surplus and better inform hunting regulations. Recent data from annual monitoring of this species has shown the potential for more harvest opportunity than we previously realized and the new strategy now allows for a maximum bag limit of three per day when the population warrants that. The new model outputs suggest that the optimal bag limit for the ‘25-’26 season will in fact be a three‑bird bag limit.

Based on recent wild turkey distribution mapping efforts by field staff, Lubbock County, as you can see here, is one of the only counties in the High Plains with known occupancy of turkeys, yet it currently does not have an established turkey hunting season. As such, staff will be proposing to add Lubbock County to the wild turkey north zone season framework for next season. More specifically, the proposal is to open Lubbock County for turkey hunting in the fall for either sex, and in the spring, for the harvest of gobblers and bearded hens. This will include a four-bird annual bag limit. This proposal has been reviewed and approved by Texas Parks and Wildlife’s Upland Technical and Advisory Committees.

With that, that concludes my presentation. I’ll take any questions. Thank you.

CHAIRMAN HILDEBRAND:  Thank you. Any questions, commissioners?

Okay. Thank you. I think we have a second. Mr.  Gray.

MR. SHAWN GRAY: Good afternoon, Mr. Chairman, members of the Commission. For the record, my name is Shawn Gray. I’m the Mule Deer and Pronghorn Program Leader, and I would like to brief the Commission on the potential proposals to the mule deer hunting regulations this January.

This map illustrates our current mule deer seasons in the state.

The yellow- and blue-colored counties have a 16‑day general season that starts the Saturday before Thanksgiving with a special archery season. The blue-colored counties are where we have implemented a mule deer antler restriction in the Panhandle. In the Trans-Pecos, those green-colored counties, we have a 17‑day general season starting the Friday after Thanksgiving with a special archery season. The light green-colored county in the Trans-Pecos is Terrell County and is where we have been experimenting with mule deer antler restriction since 2022.

The current statewide special archery season starts the Saturday closest to September 30 and runs for 35 consecutive days. All general seasons and the special archery season in all but three counties in the Trans-Pecos are buck only.

Staff have received several requests over the last few years to increase the length of the special archery season and to consolidate the Managed Lands Deer Program archery‑only and all-weapon seasons for mule deer.

The special archery season is 35 days, and staff would like to extend the Panhandle season from 35 to 56 consecutive days and the Trans-Pecos season from 35 to 62 days.

These archery season extensions would end the day before each region’s general starting date because the Trans-Pecos general season starts six days after the Panhandle. The archery extension would be six days longer in the Trans-Pecos than in the Panhandle.

The present mule deer MLDP seasons are an archery season that runs the Saturday closest to September 30 for 35 consecutive days and any lawful means season that starts the first Saturday in November and runs through the last Sunday in January.

Another potential regulation change would be to consolidate both mule deer MLDP seasons to allow for any lawful means from the Saturday closest to September 30 to the last Sunday in January.

Staff believe extending these special archery seasons and consolidating the MLDP mule deer seasons will not have any negative biological impacts to mule deer populations. In addition, staff recently conducted an online opinion survey to gauge constituent support on these potential mule deer regulation changes.

Generally, the survey recipients were hunters who bought hunting licenses in 2023 and resided in mule deer range, or anyone who reported a deer harvest from 2021 to 2023 within mule deer range through the Texas Hunt and Fish app. Landowners in the survey were those who have participated in mule deer MLDP or applied for antlerless mule deer or pronghorn permits. In total, 53,380 hunters and landowners were sent an online opinion survey by email invitation on September 10th with two reminders seven to ten days apart. The response rate was 4.3 percent, which totaled 1,951 respondents.

The first question of the survey asked the participants to define their association with mule deer. Choices were “Hunter,” “Landowner,” “Manager” and “Guide.” The majority of the respondents, 54 percent, said their association with mule deer was a hunter. 25 percent said they were a landowner and only 5 percent, a guide.

In the opinion survey, we asked, “Would you support extending the current mule deer archery‑only season in the Panhandle counties from 35 to 56 days starting from the Saturday closest to September 30 and ending the day before the general season begins?” 80 percent of all respondents and 83 percent of Panhandle respondents said they would support this change.

We also asked, “Would you support extending the currently mule deer archery‑only season in the Trans-Pecos counties from 35 to 62 consecutive days starting from the Saturday closest to September 30 and ending the day before the general season begins?” 75 percent of all respondents and 81 percent of Trans-Pecos respondents said they would support this change as well.

Lastly, we asked under mule deer MLDP, “Would you support consolidating the special archery‑only season within any weapon season which would allow for any lawful means to be used from the Saturday closest to September 30 through the last Sunday in January on properties participating in the mule deer MLD program?” About 70 percent of all respondents and over 70 percent of mule deer MLDP respondents would support this change too.

Again, staff believe extending the current special archery seasons and consolidating the mule deer MLDP seasons will not have any negative biological impacts to mule deer populations.

And with the positive feedback from the opinion survey as well as support from the Mule Deer Advisory Committee and the Texas Wildlife Association Big Game Committee, staff would like to come back to this Commission in January to request to publish these potential mule deer regulation changes in the Texas Register for public comment.

I would be happy to take any questions that you might have at this time.

CHAIRMAN HILDEBRAND:  All right. Any questions? Okay. Thank you very much.

MR. GRAY: Yeah. Thank You.

CHAIRMAN HILDEBRAND:  Let’s see. Work Session Item Number 14: 2024 Survey of Employee Engagement.

Mr.  Matt Kennedy.

MR. MATT KENNEDY: Good afternoon, Mr. Chairman, Commissioners.

My name is Matt Kennedy, and I’m with the Human Resources Division.

I’m here to share with you a quick briefing on the 2024 Survey of Employee Engagement results. A quick overview for you all on the Survey of Employee Engagement, which we also refer to as the, SEE. The SEE is simply an organizational climate survey that’s conducted by the Institute for Organizational Excellence at the University of Texas at Austin.

It is a really great opportunity for our employees to have an option to give feedback on how the organization is performing, and how they are engaging with one another in the work that the organization is doing.

All full‑time regular and part‑time employees are eligible to participate. There are several different entities who get to see the SEE. So, legislatively speaking, it is entities such as House Appropriations, Senate Finance, LBB, Sunset Advisory, executive entities such as the State Auditor’s Office. Of course, you all, the TPW Commission, see these results. Our Executive Office was briefed on them as soon as we received them, then Division Directors. And this past August, Dr. Yoskowitz shared the results with all TPWD employees.

So how does the SEE work? There are 48 primary questions that are written by the University of Texas at Austin, and they are broken down into 12 different constructs or topic areas that you see here on your screen.

There are an additional 22 questions to the survey that are written by Parks and Wildlife. They are not scored as a part of these 12 constructs. However, we will take a look at a couple of those additional questions a little bit later.

Everyone responds on a Likert scale on these 70 questions.

Anywhere from “Strongly Disagree” to “Strongly Agree.” The survey then translates those into points and scores between 100 and 500. Anything that is 350 points or above is considered strong or excellent in this survey. Spoiler alert for you: You are going to see a whole bunch of numbers in that strong and excellent category in just a second. UT does provide Parks and Wildlife with several different reports for this survey at an agency level but also at each division level as well.

Here is the Parks and Wildlife response rate to the Survey of Employee Engagement over the last several iterations. Most recently for 2024, we fell at a 75 percent response rate.

Now I know you see there was a 7 percent decrease compared to the 2022 survey. Not super concerned about that dip in response for a couple of different reasons.

First, 75 percent response rate for an organization the size of Parks and Wildlife is outstanding. Second of all, you’ll see here in just a second, even though we had a decrease in our score– or in our response rate– we actually had an increase in our overall score. From 383 up to 391.

Now, if you remember back to that point reference chart, anything 350 and above is considered strong. 400 is that standard of excellence in this survey. Parks and Wildlife’s overall score for the entire organization is almost at that standard of excellence of 400 points. That’s relatively unheard of, especially for an organization that is almost 3,200 employees. We continue to trend in the right direction in our overall score. And that is not surprising when you can look at the levels of engagement across the organization.

We had 63 percent of our employees that fell into the categories of “Highly Engaged” or “Engaged.” That is 6 percent higher than compared to the previous survey when we were at 57 percent in the same two categories. But not surprising to see that we are doing so well in these areas. We traditionally do better than most organizations largely because of our mission and the work that we get to do. But in 2024, the Gallup organization reported that all organizations across climate surveys had about 32 percent of their workforces that fell into being actively engaged. Parks and Wildlife almost 30 percent better than the average organization in that regard.

Here is how Parks and Wildlife scored on each of the 12 constructs for not just this survey but the previous two surveys as well.

That yellow bar up at the front shows the 2024 score. The green right above it is 2020. The blue below it is 2022 for your reference. You will first notice that every single score that you see here is at 350 or above with the exception of pay– of course, this is our Achilles heel, we’ll talk more about it here in just a minute.

But the other thing I’ll point out to you is that half of all of these constructs meet or exceed that standard of excellence of 400 points for this survey. And for the first time, the organization is hitting those marks in over half of those categories.

Our largest increases were “Workgroup” at 29 points. And while it does still remain relatively low, “Pay” increased at 15 points. A one‑point decrease in “Benefits” not statistically significant, although we will look at it, and a five‑point decrease in “Information Systems” which honestly is just natural regression after we had such huge increases to the score in that category between 2020 and 2022.

So first, let’s take a look at the areas of strength for Parks and Wildlife: “Workgroup,” “Supervision,” and “Strategic.”

A little bit different compared to previous surveys. Normally, “Workgroup” is fourth and it catapulted from fourth to first in this survey, and we’ll take a look at why.

The reason why actually comes on the third question that you see here. Right, you can see that the other three questions, the scores did not change a whole lot over the previous surveys.

However, that third question with the asterisk, the score jumped a lot from below 350 to well over 400. The question for 2024 reads, “In my work group, we encourage each other to learn from our mistakes.” But that question was new for the 2024 survey.

Previously, that statement in the SEE had always read, "My work group uses performance data to improve the quality of our work."

The problem with that question is that it wasn’t something that could be measured consistently across all areas of the organization. Not everyone is able to use performance data in the same ways. So, we had varying scores. Now the question measures something more relevant to “Workgroup”. And we have a more consistent score with the other three questions. Not surprising, when you get to know the people here at Parks and Wildlife, that “Workgroup” continues to be one of our strongest areas. The other reason why “Workgroup” remains number one for us also comes out of supervision here, our second strongest construct, at 415 points.

All of these had increases compared to the previous survey, but I think the ones most important to point out and really speak to workgroup and employee engagement is the ability for employees to be able to do their best work and supervisors evaluating their performance fairly. Those things are really important to us achieving our strategic vision as an organization. This is another construct that we do very well in, at 413 points for the 2024 survey, but the reason we do so well with this is that it is easy for employees across our agency to see the impact of their day‑to‑day work on the larger mission and strategic vision of Parks and Wildlife. We continue to do well here, and we can continue to leverage this toward employee engagement in the future.

So here are some areas of opportunity for the Department.

“Pay”, of course. “Benefits” was a one‑point decrease for us.

“Internal Communication”, while it shows us an area of opportunity and was our third lowest scoring construct, really is an anomaly. It doesn’t belong in the bottom three. 382 is a very, very good score. We actually had an increase compared to the previous surveys.

First, we’ll take a look at pay. 252 is a terrible score.

However, 15‑point increase compared to the previous survey is something promising, and where we see those biggest gains was, ”My pay keeps pace with the cost of living.” Some of the legislative increases that occurred over the last couple of years, in addition to some of the strategic equities that Parks and Wildlife has made a point to make in the last couple of years, has helped move the needle in a positive direction here.

However, I think we can all acknowledge it is not quite enough and there is more work to do in this arena.

The next area is “Benefits”. The reason I say a one‑point decrease is not statistically significant is not just because a one‑point decrease is not statistically significant, but it is also because we are not able to control two‑thirds of this construct. Retirement benefits and health insurance benefits are actually controlled by the Legislature. The only thing we have control over as an agency is how we are able to communicate how those benefits are able to be tailored to meet individual needs.

On that one question, we actually saw a bit of an increase for the agency because of those efforts that we continue to make across the entire organization in that regard.

The way that we do that is through “Internal communication”. It’s an area that we continue to get stronger in as an organization. At 382, this score is very, very good, but where you see some of those biggest gains for us are some of those open and honest collaborative environments in our communication.

And you’re going to see that theme come up here in just a second, too.

There is a couple of additional questions around internal communication. The three on the left are written by UT and scored in other constructs, but the one on the far right, “The flow of communication from my immediate supervisor is effective,” is a Parks and Wildlife‑specific question. And you see we have continued to trend in the right direction on this one over the last several surveys really showing why “Supervision” and “Workgroup” continue to be so strong for our organization.

Three more questions that Parks and Wildlife wrote new for the 2022 survey, and we share them with you here because we now have trend on it for the first time:

“People are more collaborative and communicative across disciplines and divisions.”

“They are able to share feedback with division directors.”

This last one is really important, “Leadership provides timely, clear communication on important matters.”

At a score of 364, it is really great to see that trend in the right direction, but that is a hard ship to turn around for an organization as dispersed as Parks and Wildlife. It’s great to see these going in that direction.

One last area we want to talk about, and that’s “Trust”.

There are two questions around “Trust” in this survey.

One is around “Workplace Trust”. It scored as a part of the “Community” construct. The other is written by Parks and Wildlife, and that’s there being trust between the Divisions.

Both of these saw increases compared to the previous survey, but I think the most important message on this slide is the increase that our organization has had in both of these questions compared to 2018 to 2024.

We have made significant strides to break down silos across the organization and within teams to ensure that that trust continues to be cemented and that we are doing a better job of reaching our overall mission.

So quick overview of the process for the Survey of Employee Engagement. Of course, we are briefing you right now here in November 2024, but we did just wrap up each division submitting a tailored action plan for their employees based off of the feedback from their divisional reports to the SEE.

They are beginning to implement the action plans across the agency with the intention of having them fully implemented before we readminister the SEE in early 2026, so that we can continue to leverage this tool to benefit one of our most important natural resources, and that is our human resources.

With that, that concludes my presentation and I’m happy to take any questions.

CHAIRMAN HILDEBRAND: Great. Any questions for Mr. Kennedy?

Okay. If not, I’ve got one.

So, Mr.  Kennedy, is there a way to parse out the data by group, division, department? Because one of the issues in here is that you get the survey, but you don’t… there are 20 percent.... That is not that high. But we do this at our company. And the most important element of a survey like this is that you proactively go take the results and then go do something about it.

MR. KENNEDY: Absolutely.

CHAIRMAN HILDEBRAND:  And the only way to do that is by a department or division. It is hard to do it with‑‑ how many employees do we have at Texas Parks…?

MR. KENNEDY: Almost 3,200.

CHAIRMAN HILDEBRAND:  It is hard to do kind of do in a broad mandate. Can you break this down by group and then go to that group and really try to ferret out what is going on there and make the changes?

MR. KENNEDY: Absolutely. So, to some degree, we are able to do that. We get division reports. All 13 divisions get their own division report. And then our larger divisions, specifically Law Enforcement, State Parks and Wildlife, get breakdowns of region‑specific reports as well. But that’s as granular as any of the data gets. Some of that is to protect anonymity of the respondents as well.

So, to answer your question, some of the things that we have done to address that exact issue in the past and for this iteration of the survey has been focus groups in the past.

Both in-person and virtual and written focus groups that have provided us a lot of feedback.

We didn’t use those targeted focus groups this time because the data hasn’t changed a whole lot coming out of the focus groups over the last six or seven years. What we did this time was we gave each division their specific report and we said drill down with your teams to create a meaningful action plan that addresses the most salient themes that came out of your division’s report. And so individually, within divisions, they did target specific groups, talked to different focus groups within their divisions to gather some additional context to the results and produce those action plans. And we are just now starting to roll those action plans out in each of those divisions.

CHAIRMAN HILDEBRAND: Good. So, will you keep the director informed on this so he can keep me informed? This is an important part of morale, that you are taking the survey, you are listening to people and then you are going and proactively and doing something about it. So, people just want to be heard and they don’t just want the results to be blown off and just as a perfunctory process do a survey. So, it really agitates them.

MR. KENNEDY: Yes, sir.

CHAIRMAN HILDEBRAND: So, push hard to implement some results relative to the survey. Okay. Great.

MR. KENNEDY: Yes, sir. Thank you.

COMMISSIONER DOGGETT: I would say real quickly. It would be very interesting to see the results of the action plan, right? So, if you could do an executive summary of what the results of the survey were, what issues that you identified, the action plan that you created and then implemented. And then, on the back side, to see the new survey and see how we improved in those areas…

MR. KENNEDY: Absolutely. Yes, sir.

COMMISSIONER DOGGETT: …or not.

MR. KENNEDY: We can definitely put that together leading into the 2026 survey so that we can all see what we did, where we are at, and then we can compare that to the new results.

COMMISSIONER DOGGETT: That would be very helpful to the team, too, so they can see the measurable results of what they are doing.

MR. KENNEDY: Yes, sir.

CHAIRMAN HILDEBRAND: I would like to see the plan that you put together for their 13 different departments.

MR. KENNEDY: I would like to say I did not put any of them together. Each division did it themselves with their leadership teams. That way it wasn’t HR dictating to them what to do. They had real ownership over doing something that was meaningful to their individual staffs. And absolutely, we will provide that to our executive leadership team to share with you all.

CHAIRMAN HILDEBRAND: Great. Commissioner Doggett is going to be concerned about the 2026 results while others on the board are not, so…

[ LAUGHTER ]

Have fun with that, Leslie.

MR. KENNEDY: We will mail them out to you, how about that?

CHAIRMAN HILDEBRAND:  OKAY.

Work Session Item Numbers 15 to 22 will be heard in Executive Session.

At this time, I’d like to announce that pursuant to the requirements of Chapter 551, Government Code, referred to as the Open Meetings Act, an Executive Session will be held at this time for the purpose of deliberation of real estate matters under section 551.072 of the Open Meetings Act, seeking legal advice under section 551.071 of the Open Meetings Act regarding pending or contemplated litigation, and deliberating the evaluation of personnel under section 551.074 of the Open Meetings Act.

We will now recess for the Executive Session at 12:48 p.m.

[ GAVEL POUNDS ]

CHAIRMAN HILDEBRAND:  Alright, Dee, we good? Six? That’ll work. Okay. Alright, thanks. We’ll now reconvene the Work Session on November 6, 2024, at 2:43 p.m. Before we begin, I’ll take role. Chairman Hildebrand, present. Vice-Chair Bell, not. Commissioner Abell?

COMMISSIONER ABELL: Present.

CHAIRMAN HILDEBRAND:  Commissioner Doggett?

COMMISSIONER DOGGETT: Present.

CHAIRMAN HILDEBRAND:  Commissioner Galo?

COMMISSIONER GALO: Present.

CHAIRMAN HILDEBRAND:  Commissioner Patton?

COMMISSIONER PATTON: Present.

CHAIRMAN HILDEBRAND:  Commissioner Scott?

COMMISSIONER SCOTT: Present.

CHAIRMAN HILDEBRAND:  And Vice-Chair Bell?

VICE-CHAIRMAN BELL: Present.

CHAIRMAN HILDEBRAND: There you go. All right. We’re now returning from the Executive Session, where we discussed the Work Session Real Estate Item Numbers 15 through 19, Centennial Parks Conservation Fund Projects, Item Number 20, Litigation Item Number 21, and Personnel Matters Item Number 22. If there are no further questions, I’ll place Items Number 15 through 19 on the Thursday Commission Meeting agenda for public comment and action. Regarding Item Number 20, I will authorize staff to begin the public notice and input process. Regarding Item Numbers 21 through 22, no further action is needed at this time.

Dr. … hold on. Okay.

The Commission has completed its Work Session and I declare… we’re not adjourned.

[ INAUDIBLE OFF MIC ]

What?

DR. YOSKOWITZ: Just the work session.

CHAIRMAN HILDEBRAND: Okay. All right. Just the work session. We are adjourned at 2:44 p.m. All right.

[ WORK SESSION CONCLUDED AT 2:44 P.M. SEE SEPARATE REGIONAL PUBLIC HEARING TRANSCRIPT. ]

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