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.
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:
[iv] Dictionary.com: 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.
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.
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.