Recently, state agencies have taken an initiative to increase the number of unannounced compliance inspections. These inspections are conducted in an effort to increase compliance from regulated entities. Unannounced inspections are on-site inspections conducted without prior notice to the regulated entity. During this time agency officials have the legal authority to enter the facility and inspect all permits, records, and sources for non-compliance related issues.


In Texas, TCEQ maintains, tracks and considers the compliance history of all entities and industries when considering whether or not to conduct an unannounced inspection. Regulated entities are classified or reclassified every September to acknowledge the compliance history of all entities in the previous five years. Entities which receive a rating below 0.10, means these entities have an “above satisfactory compliance record” with environmental regulations and are not considered for the scheduling of unannounced inspections. Entities that have received a rating from 0.10 to 0.55, means these entities have “generally complied” with environmental regulations and are also exempt from unannounced inspections. Entities that have received a rating greater than 55 means these entities have performed below the minimal acceptable performance standards” and are classified as “unsatisfactory”. Unannounced inspections are conducted for those entities that are classified as an unsatisfactory performer.

Additionally, unannounced inspections can also be a result of a complaint related inspection, enforcement follow-up, and/or other scenarios the agency suggests that these inspections are warranted.

The Air Permitting team at Fenstermaker offers proactive onsite inspections to access a facility’s compliance and mitigate risks. These inspections are recommended to avoid hefty fines, project delays and a tarnished reputation. Give us a call to schedule your inspection and analysis today.


Shoná MooreShonta’ N. Moore, MS is an Environmental Specialist at Fenstermaker with 7 years of experience in air quality compliance and regulatory applicability. She spent 5 years as a Environmental Investigator with the Texas Commission on Environmental Quality (TCEQ.) Ms. Moore possesses a Master’s Degree in Environmental Toxicology and a Bachelor’s Degree in Biology from Texas Southern University in Houston, TX. Her air permitting experience includes environmental auditing and environmental consulting for both oil and gas and power plant facilities. Ms. Moore has a working knowledge of rule interpretations, emission calculations, and compliance determinations and is efficient in Title V, NSR, and PBR permitting. Ms. Moore prepares and submits permit applications for the oil and gas industry in Texas, Louisiana, and Mississippi.