Or will they choose to remain stuck there. Because, you know, that is a
choice they are free to make.
It’s a simple proposition, really. If your aim is to maximize use of
the water resource we mistakenly call “wastewater” to defray demands on
the area’s water supplies, then it just makes sense to design the
“waste” water system around that principle. It doesn’t make sense to
instead use a large majority of the money dedicated to this function to
build a large-scale system of pipes and pump stations focused on making
what’s misperceived as a nuisance to go “away”, then to spend even more
money on another large-scale system of pipes and pumps to run the
reclaimed water back to where it came from in the first place!
That’s the standard MO of our mainstream institutions, like the City
of Dripping Springs and the engineers who advise it and developers whose
projects would feed into the city’s centralized wastewater system. This
centralized management concept was a response to the conditions
considered paramount in the 19
th century. The industrial
revolution was in full force, city populations were exploding, the stuff
was littering the streets, creating a stench and a serious threat of
epidemic disease. The response was to pipe it “away”, to be deposited in
the most conveniently available water body. Later, as it was realized
those water bodies were being turned into foul open sewers, creating a
threat of disease in downstream cities that withdrew their water
supplies from them, treatment at the end of the pipe was considered, and
eventually adopted as the standard.
The intellectual leadership of the centralized pipe-it-away strategy
was centered in well-watered areas like northern Europe and the
northeastern and midwestern areas of the US. So the resource value of
that “waste” water was never part of the equation. This water, and the
nutrients it contains, was viewed solely and exclusively as a nuisance,
to be made to go to that magical place we call “away” – the working
definition of which is apparently “no longer noticeable by me.” This
centralized pipe-it-away strategy became institutionalized as
the manner in which cities manage wastewater.
Of course, that strategy flies in the face of the circumstances confronting us here in Central Texas in the 21
st century – that water,
all
water, is a valuable resource which we can no longer afford to so
cavalierly waste by addressing it solely and exclusively as if it were
just a nuisance, simply because that is what the prevailing mental model
dictates. Rather, it’s imperative we practically maximize the resource
value of that water, using it to defray demands on the area’s water
supplies, which are being stressed by both chronic drought and
population growth.
In the Texas Hill Country, we also have an issue with surface
discharge of wastewater, even when treated to the highest standards that
the Texas Commission on Environmental Quality (TCEQ) has so far
formulated. And before proceeding I’d note that this issue would remain
even if the whole system were to operate perfectly all the time. But of
course, it will not; there will inevitably be “incidents”. Which brings
up the issue of the
vulnerability created by
centralization. I’ve often said, not entirely tongue-in-cheek, that the
real point of regionalization – TCEQ-speak for centralizing flow from as
far and wide as can be attained – is to gather all this stuff together
at one point where it can
really do some
damage. Indeed, the whole organizational strategy is a “vulnerability
magnet”. Large flows being run through one treatment plant or one lift
station or one transmission main means that any mishap may create large
impacts.
Back to the issue with discharge in the Hill Country, the major
problem is those nutrients in the wastewater, in particular nitrogen. A
discharge of the magnitude that an expanded Dripping Springs system
would create, centralizing wastewater flow from developments for miles
around the city in every direction, would make the receiving stream
effluent-dominated. This would be partly an artifact of the drawdown of
local aquifers drying up springs and thus reducing natural streamflow –
again highlighting how critical it is to defray demands on these local
water resources – but in larger part due simply to the magnitude of the
wastewater flow. Highlighting the problematic nature of “permitted
pollution” when the flow has been centralized so that, even with low
concentration limits, the mass loadings may still be “large”. The
nitrogen would cause chronic algal blooms in the creeks, making them
very green most of the time, and then depleting oxygen in the water when
the algae die off, degrading the riparian environment.
This is deemed an aesthetic affront by downstream landowners. But
even more critical, the stream that would receive Dripping Springs’
discharge is Onion Creek, a major source of recharge to the Edwards
Aquifer. That’s a sole source aquifer supplying water to about 60,000
people and is the source of Barton Springs, which is home to endangered
species. So there’s great antipathy to any plan by Dripping Springs to
discharge.
The “standard” option is to continue to “land apply” the effluent
from its wastewater treatment plant – “irrigating” land for the sole
purpose of making the water go “away” rather than to enhance the
landscape or grow a cash crop – which the city does under its current
permit. This practice is more accurately termed “land dumping”, and in
this region, in this time, it is an unconscionable waste of this water
resource.
At least discharge would have some utility, providing more constant
flow in the creek, enhancing the riparian environment, and a more
constant recharge of the Edwards Aquifer. That is, it would have utility
if the water were to be treated to a standard that would preclude the “insults” noted above.
In regard to nutrients, that is technically possible – albeit
unlikely to be required by TCEQ – but it would be quite expensive.
Burnet discovered that treating to a higher standard to allow them to
discharge into Hamilton Creek, which eventually flows into the Highland
Lakes, would add about $10 million to the cost of their treatment plant.
But that still won’t attain the high removal rate demanded for
discharge into Hill Country creeks that recharge the Edwards Aquifer.
But nutrients aren’t all there is to be concerned about. There are
also “contaminants of emerging concern” – pharmaceuticals, in particular
endocrine disruptors. What it would cost to make discharge “safe” in
this regard is an open question – another subject for another time.
Suffice it to note here that TCEQ has no standards addressing these
pollutants, thus there is no requirement to even consider what might be
“safe”.
The latest word is that the overwhelming dissatisfaction with a
discharge scheme has urged Dripping Springs to drop its plans to seek a
discharge permit – for the present. It’s unclear if that means it would
just expand its “land dumping” system (a rather costly proposition, due
to the land requirements, so Dripping Springs might soon decide that’s
just too expensive and
would request a permit
to discharge). Or would the city pursue any and all opportunities to
route the treated effluent to beneficial reuse? Likely mainly within the
developments generating the flow as few other opportunities have been
identified, the 8-acre city park being the only one mentioned in the
version of the Preliminary Engineering Planning Report (PERP) the city
released last summer.
Which brings us to how the city would create a system plan predicated
on beneficial reuse of this water resource to defray demand on other
water supplies. The city appears to be leaning toward simply appending
onto the already costly 19
th century conventional centralized
wastewater system another whole set of costly infrastructure to
redistribute the water, once treated, back to the development that
generated it. Note, however, that as TCEQ presently interprets its
rules, the city will still be required to have a full-blown “disposal”
system in place regardless of how much of that water they expect to
route to beneficial reuse, making that whole concept somewhat
problematic if indeed no discharge option would be sought. This focus of
TCEQ rules, as currently applied, on “disposal” of a perceived
nuisance, to the exclusion of focusing on
integrated management of water resources, is an issue for any sort of plan the city may consider, highlighting the need to press TCEQ to reconsider that focus.
Indeed the city’s centralized plan would be costly. Dripping Springs
is keeping its present engineering analyses close to the vest, but
according to the version of the PERP released last summer, the three
interceptor mains in that plan – denoted “east”, “west” and “south”
(leaving us to wonder what will be done with development that may occur
to the north) – and their associated lift stations would have a total
cost of about $17.5 million. These are costs, along with the estimated
$8.1 million for treatment plant expansion and an estimated
$1 million for permitting,
that must be sunk into the system prior to being able to provide
service to the first house in the developments this system would cover.
Then there is the cost of centralized collection infrastructure within
the developments, to get their wastewater to those interceptors, no
doubt running into the 10’s of millions at complete buildout.
And for this, all they get is “disposal” of a perceived nuisance!
With, as noted, the issue of how the water would be “disposed of”, if
it is not discharged, still to be resolved – and paid for. If it is to
be redistributed back to the far flung developments generating the flow,
the facilities to do that will add many more millions to the overall
cost of the complete system.
Far less costly, in both up-front and long-term costs, would be the creation of a 21
st
century system that would be designed around reuse, rather than
“disposal”, of this water resource right from its point of generation.
The city could pursue a
decentralized concept
strategy, focused on treatment and reuse of this water as close to where
it is generated as practical, obviating the high cost of both the
conventional centralized collection system and the reclaimed water
distribution system.
Entailing a number of small-scale systems
designed into rather than
appended onto
development, it is highly doubtful that the city could unilaterally
impose that sort of system. The large developments around Dripping
Springs are all planning – indeed they have obtained TCEQ permits for –
smaller conventional centralized systems within each of them, featuring
“land dumping” as the intended fate of the water. In fact, Dripping
Springs has “sponsored” the permit for one of those developments, so is
actively promoting this strategy. The development agreement with another
large project specifies that the wastewater generated in that
development
must be run into the city
interceptor whenever it is built, despite the development-scale system
being in place. So if the city does develop interceptors that would
drain wastewater from those developments to an expanded centralized
plant, then these development-scale systems would be stranded assets,
sunk costs incurred simply to allow development to begin prior to
completion of the city interceptor, then to be abandoned, basically
wasting the fiscal resources required to install them.
It’s clear then that Dripping Springs could pursue a decentralized
concept strategy to expand service capacity to encompass those
developments only if each of them were to cooperate in planning,
designing, permitting and implementing the decentralized system, instead
of those development-scale centralized systems they’re presently
planning to build. But of course, unless Dripping Springs presumes a
leadership role, the developers have no impetus to consider that. They
must presume they’d have to abandon
any sort
of development-scale system and run their wastewater “away” into the
city’s centralized system whenever interceptors were extended to their
properties.
To pursue a decentralized concept strategy it must be determined how
such a system would be organized and how it could be permitted, given
the “disposal”-centric focus of how TCEQ wields its rule system. This is
a complex subject that does not well lend itself to this medium.
Complicated by the decentralized concept remaining “non-mainstream”
despite it having been out there for quite a long time – I defined the
decentralized concept in 1986, and it was “ratified” as a fully
legitimate strategy in a 1996 report to Congress, among other milestones
– so its means and methods remain largely unfamiliar to regulators,
engineers and operating authorities. Further, being designed into rather
than appended onto development, the details would be sensitive to
context; while there are recognized organizing principles, there is no
“one size fits all” formula.
For the interested reader, a broad overview is “The Decentralized
Concept of Wastewater Management” (in the “Decentralized Concept” menu
at
www.venhuizen-ww.com), and a basic review of those organizing principles are set forth in
this document,
reviewing wastewater management options in the nearby community of
Wimberley. But a review of exactly how to design a decentralized concept
system for any given project in and around Dripping Springs is properly
the subject of a PERP for each project, not something that can be
credibly described here, absent any context. The means and methods are,
however, all well understood technologies that can readily be
implemented to cost efficiently maximize reuse of this water resource.
Highlighting that the most salient feature of a decentralized concept
strategy in the context of this region is the “short-stopping” of the
long water loops characteristic of the conventional centralized
strategy, so that reuse of the water resource
would be maximized at the least cost. It is this 21
st
century imperative that should motivate Dripping Springs and the
developers working in that area to explore the decentralized concept. A
necessary part of that exploration is to press TCEQ to consider how it
interprets and applies its present rules, and perhaps to consider the
need for “better” rules that recognize our current water realities. None
of this can be served up for the city or the developers as a fait
accompli in this medium; it is a job they have to undertake. One which
we all need them to undertake, for the benefit of this region’s citizens, current and future.
But from all indications to date, it does not appear they will even
try – they just can’t seem to expand their mental model of wastewater
management to encompass it. The result of which is that most of this
wastewater will live down to its name for a long time to come, driving
us ever further away from sustainable water. So the question is posed:
Can Dripping Springs, and the developers there, bust out of the 19
th century – or will they choose to remain stuck there?
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It's
in the news and on the minds of many - the ongoing drought in
California, now entering its fourth year. In the face of growing water
constraints, some 
