Comment by apical_dendrite

6 hours ago

This Inside Climate News article is a little clearer.

> TCEQ began its investigation after workers for Nueces County Drainage District No. 2, which presides over the ditch area, found an unfamiliar pipe stretched across the district’s easement, expelling black liquid into the ditch

> The permit didn’t allow Tesla to use private or public property to transport the wastewater. Under the permit, it was Tesla’s responsibility to acquire whatever property rights were required to use the discharge route, the TCEQ permit states.

So one issue is that while they may have had a permit to dump wastewater, they didn't have a right to build a pipe on land controlled by the drainage district. Tesla, not TCEQ, needed to notify the drainage district because Tesla was the one building on land controlled by that district.