Wednesday, January 14, 2015

LCRA Water Management Plan - TCEQ Stakeholder Mtg. Jan. 7

The TCEQ will hold a stakeholder input meeting on
the LCRA Water Management Plan
January 7, 2015, 10:00 a.m.
TCEQ's Offices at 12100 Park Thirty-Five Circle
Building E, Room 201, Austin, Texas.   

"As part of the TCEQ's review of LCRA's amended water management plan (WMP), TCEQ is holding a stakeholder meeting to obtain input from Colorado River Basin stakeholders," Deputy Director L'Oreal W. Stepney said in a letter sent out on December 11, 2014. "We are specifically seeking comments on the amended application and TCEQ's report; however, any information is welcome."  "If you are unable to attend the scheduled meeting, you may submit written comments by January 30, 2015."  Click to see TCEQ notification letter for details.  
Environmental Stewardship (ES) has prepared extensive comments in a letter that will be submitted to the agency (and distributed through our network) and presented as oral comments at the stakeholder meeting.
ES' comments are based on Water Management and Planing Principles developed by a group of stakeholders in the basin.  Those principles form the foundation of the comments contained in the letter. The following is part of the opening remarks: 

ES will attempt to show, through its letter and input throughout the remaining portion of this review process, that:


A1. External factors have had catastrophic impacts: The current drought has demonstrated that the current water management plan (WMP) has not adequately addressed several external factors[i] that have catastrophically impacted the basin, and, if left unchecked, will sabotage any attempt to meet the WMP's objectives unless likewise managed.

A2. The extent and severity of this drought is man-made: The drought has demonstrated that, though the lack of rain[ii] has brought us to this condition, the extent and severity of the drought is primarily a man-made phenomenon. This drought is likely worse than the drought-of-record due to man's management practices and unrealistic expectations[iii] (some of which have been codified in law).
A3. Conjunctive management is needed: Future management practices will, of necessity, need to include conjunctive[iv] management of the land, the surface waters, and the aquifers that intersect the basin.
A4. Environmental flows are essential: Future management practices must guarantee a solid base of environmental flows to meet critical subsistence and threshold flow needs of the river and bay[v]. Environmental flows are essential water demands.

Environmental Stewardship is especially interested in gaining agreement and support that the WMP guarantee

essential safety net environmental flows for the river and bay. 
 and include "LCRA WMP" in the subject line of your email.  

[i] In the upper contributing zone: the impacts of the following on Highland Lake inflows: Lack of brush control, small surface water impoundments, agricultural use of groundwater for irrigation (especially cotton). In the cities: the impacts of over-sizing water treatment and distribution systems such that they cannot be safely operated at reduced/drought flow levels without dropping below residual chlorine standards.
[ii] Rainfall records and trends tend to indicate that rainfall over the contributing zone of the upper basin has been as much as 30% greater during the first six years of the current drought when compared to the same period in the DOR.
[iii] It is not reasonable to expect that water supply will be adequate in drought and severe drought conditions to enable the supply and use of the same amount of water to FIRM customers during drought as these customers receive during wet conditions. There needs to be a means of recognizing and supplying "essential needs" while reducing and/or eliminating non-essential uses. Unfortunately this expectation has been written into the adjudication orders that created the LCRA water management plan and the terms and conditions the LCRA must meet in managing FIRM vs interruptible water.

[iv] conjunctive /kənˈdʒʌŋktɪv/ adjective1.joining; connective 2.joined 3.of or relating to conjunctions or their use 4.(logic) relating to, characterized by, or containing a conjunction noun5.a less common word for conjunction (sense 3) Derived Forms conjunctively,adverb.Word Origin C15: from Late Latin conjunctīvus,from Latin conjungereto conjoin.

[v] Lacking such line-in-the-sand safety-net practices, the Colorado river will, like the Rio Grande and the western Colorado River, cease to flow to its bay and cease to be a sound ecological environment. The lack of freshwater inflows will bring dramatic ecological and economic impacts to the bay system and those who depend on the bay for a livelihood ... and on Texas heritage.

After a month of stakeholder meetings the LCRA Water Management Plan Amendments were approved by the LCRA Board and will be sent to Texas Commission on Environmental Quality (TCEQ) for review and approval. Stakeholders made adjustments to the proposed plan that improved environmental flows to the bay during drought conditions and provided improvements in interruptible flows to irrigation interests.   With these improvements, the stakeholders supported moving the plan to TCEQ for final review and approval.  The plan must be approved by TCEQ before it can be implemented. 

It isn't a perfect plan but it's the best we can do at this point in the process.   Though environmental flows to the bay were improved slightly, Matagorda Bay and its estuaries are still at significant risk during a repeat of the drought of record like we are currently experiencing.  Scientific studies, done during the LCRA-SAWS project, provide a wealth of information on what the river and bay need to stay healthy during drought, dry, and wet periods.  "Threshold" inflows to the bay, the most critical life-support for the bay during drought, are well below attainment levels approved by the TCEQ for the Colorado River and Matagorda Bay (see sidebar below for details). 

The LCRA Board, at the same meeting, approved funding for the Lane City Reservoir Project that will construct a 40,000 acre off-channel reservoir in Wharton County.  Though the reservoir will be of great benefit to the Highland Lakes, firm water customers and irrigation interests in the lower basin, it comes at a direct cost to the already stressed bay.  The reservoir is projected to capture as much as 90,000 acre-feet of water per year (filling the reservoir twice) that would otherwise flow into Matagorda Bay. As we proceed with final development of the Highland Lakes Water Management Plan, we will also need to amend the plan to take this new reservoir into consideration and secure the safety net on the bay and estuaries system

Environmental Stewardship's concerns:
After meeting with the LCRA staff and reviewing the modeling data, Environmental Stewardship submitted comments, and follow-up comments, to the staff and final comments to the Board that made the following points: 

1) The LCRA has made changes to the TCEQ recommended framework that arbitrarily deny water for environmental flows and do not adequately protect Matagorda Bay and estuaries. Though these concerns were reduced, they were not eliminated.

2) The LCRA has added a "caps model" that arbitrarily reduces water provided for environmental flows during critical drought periods while making more water available in "good times".  Again, these concerns were reduced, but not eliminated. 

3) The LCRA continues to demand surface water for power plant operations even though it has recently obtained permits from the Lost Pines Groundwater Conservation District for groundwater to supply the Bastrop Power Plant.  The LCRA staff included the groundwater use at the Lost Pines power plant.  This adjustment in the model resulted in increased flows in the lower basin and a 5,000 acre-foot/year increase in the combined storage of the Highland Lakes.   This is a very good and constructive amendment to the plan.   

Environmental Stewardship is especially interested in gaining agreement and support that the WMP guarantee

essential safety net environmental flows for the river and bay. 

 and include "LCRA WMP" in the subject line of your email.  

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