South Central Texas Regional Water Plan

ERRATA SHEET

This Errata Sheet is submitted by the South Central Texas Regional Water Planning Group (SCTRWPG) in response to a review of the South Central Texas (Region L) Adopted Regional Water Plan (January 4, 2001) by the Texas Water Development Board (TWDB). The TWDB review was transmitted in the form of a letter dated March 28, 2001 (Attachment 1) with an attached Interoffice Memorandum dated March 23, 2001 (Attachment 2) enumerating the detailed findings of the review. The SCTRWPG response to each of the detailed findings is presented within the text of Attachment 2 and in Attachments A through E that provide additional information regarding specific findings of the TWDB review.

July 13, 2001

Attachment 1

Texas Water Development Board Review Letter of March 28, 2001

March 28, 2001

Mr. Greg Rothe, General Manager via facsimile: 210-227-4323

San Antonio River Authority

Address

Ms. Evelyn Bonavita, Chairman via facsimile: 210-828-1627

South Central Texas Regional Water Planning Group

at her home address

Ref: Review of the South Central Texas (Region L) Adopted Regional Water Plan

Dear Mr. Rothe and Ms. Bonavita:

At the February 21, 2001 Texas Water Development Board (TWDB) meeting, TWDB staff presented a process and timeline for review of adopted regional water plans (Attachment 1). The process we laid out to our Board included an analysis of whether eight key issues are satisfactorily addressed by the adopted regional water plan. If the key issues are satisfactorily addressed, then staff could recommend approval of the adopted regional water plan. Otherwise, issues associated with each regional water plan would be forwarded to the regional water planning group and designated political subdivision.

In our communications with the regional water planning groups, staff is to indicate whether the adopted plan can be revised with or without a plan amendment. A plan revision would require favorable action by the regional water planning group at a regularly posted meeting; whereas, a plan amendment would require re-adoption of the plan by the regional water planning group in accordance with provisions of Texas Administrative Code §357.11(e) after a public hearing is held. Examples of revisions requiring a plan amendment include:

(1) addition of a water management strategy to meet a need,

(2) a significant change to a recommended water management strategy to meet a need,

(3) addition of water management strategies to meet needs that were not previously identified in the adopted regional water plan.

At this time, Board staff has completed the review of the adopted South Central Texas Regional Water Plan. The review finds several areas where revisions, corrections, clarification, or submittal of additional information are necessary. The key findings resulting from the staff review are the following:

1. For certain planning elements, the adopted regional water plan does not satisfactorily address the general provisions for planning included in statute and rules.

a. 31 TAC 357.5(d)(1) and 357.7 (a)(2), regarding use of state-approved population projections; the staff review identified various instances where the adopted plan does not reflect use of TWDB approved population projections.

b. 31 TAC 357.5(e)(1) and 31 TAC 357.7(a)(7)(B), regarding evaluations for effect on environmental water needs, as applied to Lower Colorado River Diversions. Staff finds that the Region L plan does not comply with the state environmental consensus criteria.

c. 31TAC 357.7(a)(7) (G), regarding consideration of the provisions in the Texas Water Code, §11.085(k)(1) for interbasin transfers [IBT], and 31 TAC 357.5(f), requiring the regional water planning group to prepare its regional water plan to be consistent with all laws applicable to water use in the regional water planning area. Staff finds that the plan is in error in its representation of the Lower Guadalupe River Diversions as a non IBT. Also, staff finds the plan includes a water management strategy that reflects an instance of use of Edwards aquifer water in conflict with existing law.

d. 31 TAC 357.7 (A)(7), regarding documentation that water management strategies have been evaluated in accordance with the specified criteria; and, 357.8 (A), requiring that plans to meet needs be described in sufficient detail to allow state agencies to make financial or regulatory decisions to determine the consistency of the proposed action before the state agency with an approved regional water plan. The plan lacks documentation of the evaluation of the San Antonio Water System Recycled Water Program which is presented as a recommended water management strategy.

e. Consequently, as a result of the issues noted under items b though d, above, the plan does not meet 31 TAC 357.7(a)(7) (F), regarding the need for the plan to present an equitable comparison and consistent application of all water management strategies; and, 31 TAC 357.5(e)(4), requiring that the plan provide specific recommendations of water management strategies based upon identification, analysis, and comparison of all water management strategies the regional water planning group determines to be potentially feasible so that the cost effective water management strategies which are environmentally sensitive are considered and pursued, where appropriate.

2. TWDB staff finds that not all TWDB-issued comments are satisfactorily addressed. These comments range from minor corrections in TWDB-required data tables to compliance with interbasin transfer requirements.

3. The staff review finds that there are two instances of interregional conflicts to be considered in the assessment of this plan for future approval recommendation. First, a conflict due to inconsistencies in the reporting between the Regions K and L plans regarding the Colorado River Diversion; and second, a conflict resulting from the Region L proposed pumping levels out of the Simsboro aquifer in Bastrop County which exceed the limits set by the groundwater availability policy adopted by the Region K.

It is our opinion that a plan revision is necessary in order for us to recommend your plan for approval by our Board. If the revisions to the plan result in additional water management strategies being recommended, or in significant changes to the currently recommended water management strategies, then the plan will need to be re-adopted in accordance with the requirements described in 31 TAC 357.12.

Detailed findings of the review are contained in Attachment 2.

Please be advised that revisions to the adopted regional water plan will need to be

corrected in the form of an errata sheet that is approved at a public meeting of the regional water planning group. The errata sheet must contain specific instructions on pages/sections in the adopted plan to be replaced, added, or deleted such that Board staff and the general public can update their adopted regional water plans. In addition, the comments contained in Attachment 2 along with your written response must be included as part of the errata sheet. The Board requires one unbound camera-ready original, one electronic copy, and nine double-sided copies of the errata sheet with all supporting documentation (if any). In addition, the errata sheet must be provided to all known recipients of the adopted regional water plan.

At this time, staff anticipates presenting your plan for to our Board for their consideration no later than our June 20, 2001 Board meeting. In order to review your revisions and meet deadlines related to the June Board meeting date, you will need to submit your errata sheets to us no later than May 18, 2001. Please contact Jorge A. Arroyo at (512) 475-3003 if you have any questions or need additional information.

I look forward to receiving the additional information from you and being able to make a favorable recommendation to our Board.

Sincerely,

Tommy Knowles, Ph.D., P.E.

Deputy Executive Administrator

Office of Planning

cc: South Central Texas Regional Water Planning Group Members

Attachments (2)

Attachment 2

Texas Water Development Board Interoffice Memorandum of March 28, 2001

and

South Central Texas Regional Water Planning Group Responses

INTEROFFICE MEMORANDUM

TO: Tommy R. Knowles, Deputy Administrator for Office of Planning

THRU: Bill Mullican, Director, Water Resources Planning

FROM: Jorge A. Arroyo, Assistant Director, Water Resources Planning

DATE: March 23 2001

SUBJECT: Initial Review of the Regional Water Plan Adopted by the South Central Texas Region.

In a memorandum to the Board dated February 14, 2001, the Water Resources Planning Division formulated a process for the review and approval of the adopted regional water plans. This memorandum reports the results of the first step of that process as applied to the review of the Regional Water Plan adopted by the South Central Texas Regional Water Planning Group (SCT RWPG) and presented to the TWDB on January 5, 2001. The initial review of the adopted plan finds several areas where corrections or clarification of information are necessary in order to consider the plan for approval.

The review focused on the key issues listed in the February 14, 2001 memorandum.

A. Determinations of whether the plans were developed according to the general provisions for planning included in statute and rules.

The initial review of the adopted plan finds that the following requirements have not been met.

1. 31 TAC 357.7 (a)(2) and 357.5(d)(1), regarding use of state-approved population and water demand projections.

a. The adopted plan contains one remaining instance of a population projection differing significantly from the state approved projections [Dewitt County-other, 2040 population should be 8,631; the plan reports 11,631].

SCTRWPG Response: The data mentioned for DeWitt County, County Other are correctly included in the text of the South Central Texas Regional Water Plan, Volume I, Table 2-3, on pages 2-7, 2-8, 2-9, and 2-10. The difference is in Exhibit B, Table 1, which has been corrected in Exhibit B, Table 1, and transmitted in electronic format to the TWDB. No changes are made to the text of the Plan.

b. There are several instances of single-digit differences between the TWDB approved values and the reported values due to rounding errors.

SCTRWPG Response: There is one case of population and six cases of water demand differences between TWDB projections and values included in the South Central Texas Regional Water Plan. Each is listed below, together with table and page location in the Regional Water Plan.

The one case of a difference between TWDB population projections and a population entry in the South Central Texas Regional Water Plan is a difference of one person for Kendall County, County Other (Rural) in 2020. The TWDB projection for Kendall County, County Other is 35,498. The value in the Water Plan, which includes the sum of 3 entries (San Antonio, Guadalupe, and Colorado Basins) for Kendall County, County Other (Table 2-2, on pages 2-7 and 2-9 of the Regional Water Plan) is 35,499, or one more person than the TWDB projection. This appears to be a transcription error for 2020, since the entries for 2000, 2010, 2030, 2040, and 2050 are in agreement with the TWDB projections. Exhibit B, Table 1 has been corrected, but since the difference has no effect upon the results of the South Central Texas Regional Water Plan, no changes were made to the text of the plan.

The water demand differences are for: (1) Atascosa County, County Other; (2)Calhoun County, County Other and Mining; (3) Kendall County, County Other; (4) Comal County Irrigation; and (5) Wilson County Irrigation. The TWDB Projections and Regional Water Plan entries of differences are tabulated below, together with the table number and the pages of the text on which the entries are located.

Atascosa County, County Other