What WOWSC Members Should Know about TCEQ Violations

If you’ve read the recent letter from the Windermere Oaks Water Supply Corporation (WOWSC) Board, you might have walked away thinking our water system is on the brink of collapse. Words like “violations” and “mandated upgrades” can sound scary, especially when they’re presented without context. Our current Board leadership is particularly good at alarmist exaggerations.

Windermere’s Track Record

The Texas Compliance & Enforcement Search Portal is a public tool that lets anyone look up regulatory records for utilities across the state.

To check on Windermere Oaks, you would simply enter “Windermere Oaks Water Supply Corporation” into the search bar. The portal will then display any compliance or enforcement actions recorded by the Texas Commission on Environmental Quality (TCEQ), including notices of violation, enforcement orders, or penalties. This makes it easy for members to see the official history of violations and confirm whether issues are minor (like paperwork errors) or more serious.

What You Will See

Here is graphic of what you will see. In sum, 1 complaint about low water pressure in 2020. Resolved. One notice of violation in 2022. Another notice of violation in 2024.

When people hear the word “violation,” it’s easy to imagine the worst — unsafe water, health risks, or a system in crisis. But not all violations carry the same weight. In fact, TCEQ Category B Violations sit right in the middle of the severity scale.

Category B violations are intermediate issues. They’re more serious than simple paperwork mistakes, but they don’t rise to the level of immediate health threats. Think of them as warning lights on your car dashboard: they don’t mean the engine is about to explode, but they do mean something needs attention. Common examples are a utility failing to maintain required treatment equipment; Improper operation of wastewater facilities; or repeated monitoring or reporting failures.

These are operational or compliance gaps — important to fix, but not the kind of problems that make your water unsafe overnight.

When TCEQ identifies a Category B violation, the utility usually receives a Notice of Violation (NOV) as you will see in the graphic. This is essentially a formal reminder: “Here’s what went wrong, and here’s the timeframe to correct it.” Utilities are expected to respond quickly, document their fixes, and prevent the issue from recurring.

For consumers, Category B violations are worth noting but not panicking over. They don’t usually pose an immediate health risk, but if ignored, they can snowball into bigger compliance problems. The real danger comes when utilities fail to correct them, allowing small issues to become systemic.


The main takeaway — these were RESOLVED!!!


Why the Alarmist Tone?

SO WHY IS THE BOARD SO ALARMIST AND MISLEADING!!!!

The Board’s letter paints a dire picture, but the facts don’t match the drama. Yes, every utility has maintenance needs. Yes, upgrades cost money. But implying that our community is drowning in dangerous violations simply isn’t accurate.

It’s important to distinguish between real risks and regulatory housekeeping. Otherwise, members are left worrying unnecessarily.


Transparency is good. Accountability is good. But alarmism helps no one especially when we are considering a major sale of our local water utility, knowing that a for-profit company, backed by private equity investors, is going to squeeze our system and us ratepayers at every possible opportunity.

As members, we deserve clear information — not exaggerated claims. The record shows our water system has been safe, with only minor administrative hiccups in the last ten years.

So the next time you see “TCEQ violation” in a headline or letter from our Narcissistic Board, remember: context matters.

Is the Windermere Oaks Water Board Narcissistic?

The water Board is enraged that members would dare ask questions about the sale of the neighborhood water company in a No-Bid, no appraisal, no advertisement manner. (By the way, all of these are attributes which the same people — the ConCouple — lodged against the 2015-16 Board, starting the decade-long legal feud they propagate.)

But back to the main topic. The Board came out Sunday and yesterday with letters to the membership about the people asking the questions, without addressing the questions.

So I decided to run the Board’s letter through an AI analysis, asking whether it demonstrates narcissistic traits, especially since it is so enraged.

Here’s what the AI analysis said. Enjoy!:


Key Narcissistic Traits in the Letter

1. Self-Promotion & Grandiosity

  • The Board repeatedly emphasizes that only they have brought “transparency, accountability, and professionalism” to the utility.
  • Statements like “This Board is the first to confront these issues head-on” elevate their role as uniquely heroic, positioning themselves as saviors of the community.
  • The phrase “The facts and evidence speak for themselves” implies infallibility and discourages dissent.

2. Blame-Shifting & Villainizing Others

  • The former president is portrayed as deceptive, irresponsible, and the root of all problems.
  • Past leadership is described as “inconsistent,” “diverting money,” “financial mismanagement,” and “undisclosed violations.”
  • This repeated scapegoating creates a narrative where the current Board is flawless and all failures belong to predecessors.

3. Control of Narrative

  • The letter frames dissenting voices as “misleading statements” or illegitimate tactics.
  • By labeling alternative perspectives as false or harmful, the Board positions itself as the sole source of truth.
  • The insistence on “100% transparency” while simultaneously dismissing member concerns about CSWR reviews suggests selective transparency.

4. Dismissal of Criticism

  • Concerns about CSWR’s reputation are minimized by comparing them to negative reviews of hospitals, banks, and airlines—implying critics are unreasonable.
  • This rhetorical move invalidates member worries rather than engaging with them substantively.

5. Moral Superiority

  • The Board frames its actions as not just practical but morally correct: “Why would any board hide information like TCEQ violations… one must ponder that question.”
  • This rhetorical question implies that only dishonest or corrupt leaders would act differently, reinforcing their moral high ground.

6. Appeals to Loyalty & Validation

  • The closing thanks members who expressed “strong, positive support,” reinforcing an in-group dynamic where agreement equals virtue.
  • This creates pressure for members to align with the Board’s narrative to be seen as supportive and community-minded.

Overall Assessment

The letter shows narcissistic tendencies:

  • High self-praise and scapegoating of predecessors
  • Dismissal of dissent and moral superiority framing
  • Validation-seeking through appeals to supportive members

But it also contains legitimate organizational communication aimed at persuasion and transparency. The narcissistic qualities emerge mainly in tone and framing.

Why I’m Voting NO on the Sale of WOWSC (Part 2)

I’m voting NO because the Board failed to seek independent valuation or competitive offers—violating basic business ethics and best practices. (And my NO vote could be changed if a better process and better contract is adopted by the Board in the future!)


The Board’s decision to move forward with the sale of our water system to Central States Water Resources (CSWR) lacks the most basic due diligence.

As confirmed at the October 25 town hall meeting by CSWR representatives, no independent appraisal was conducted by the Board of Directors. Only CSWR representatives made an internal evaluation.

Would you sell your house based only on the buyer’s appraisal of your home’s value?

It’s a violation of fundamental business ethics.

“We do have private investors or private equity money… they do have certain requirements that have to stay in the agreement that we don’t have a lot of flexibility on.”
— Sean Nichols, CSWR VP, Transcript at 00:32:25

“We’ll send you a draft. We have a standard purchase agreement. Probably 80% of the parties just sign it without any changes.”
— Sean Nichols, Transcript at 00:32:25

This confirms that the Board accepted CSWR’s terms without seeking competing offers or independent valuation. That’s unacceptable.

Just because 80 percent of other parties jump off a bridge does not mean that Windermere needs to do so also.

What Ethical Business Practice Requires

Don’t take my word for this horrible development in Windermere.

According to the Uniform Standards of Professional Appraisal Practice (USPAP), ethical valuation requires:

  • Objectivity and impartiality: Sellers must not rely solely on the buyer’s valuation ValuAdder.
  • Avoiding conflicts of interest: A buyer’s appraisal is inherently biased toward their interests oneappraisalgroup.com.
  • Transparency and accountability: Sellers should disclose how valuations were obtained and ensure they are independently verified oneappraisalgroup.com.

Best Practices in Business Sales

Any competent seller—whether in real estate, utilities, or corporate assets—should:

  • Obtain an independent appraisal to determine fair market value oneappraisalgroup.com ValuAdder.
  • Solicit multiple offers to ensure the best deal for stakeholders.
  • Disclose alternatives to members before asking for a vote.

In our case, two other water companies already operate nearby and could express interest if invited to the bidding table:

  • Corix Utilities, which serves Ridge Harbor and already has an emergency interconnect with WOWSC.
  • Aqua Texas, which operates in Barton Creek Lakeside.

These companies could benefit us by better economies of scale, lower rates, or more favorable terms. Both companies are looking to expand in this region and would probably like to add to their systems.

But the Board didn’t even ask them. Or if they did, they have not disclosed that to Members.

This Vote Deserves Better

We, the members, deserve a transparent process that compares multiple offers and includes an independent valuation. Until that happens, I’m voting NO.