Section 7
Regional Water Plan Adoption

7.1       Facilitation

7.1.1    Overview

From the outset of the planning process, the South Central Texas Regional Water Planning Group decided to emphasize a consensus approach to decision-making. That process has been facilitated first by the members' awareness of the need for cooperative and open attitudes when dealing with controversial issues. In addition, the Chair has fostered an atmosphere of fairness and open dialogue during the regular meetings of the RWPG. The group has also used an independent facilitator to assist with special meetings and workshops devoted to building consensus on specific elements of the planning process. This process has also drawn extensively on the major public involvement effort that has kept the RWPG members informed at critical times of the full range of ideas, values and concerns of constituencies throughout the region. This is an on-going process that will continue through adoption of the final Regional Water Plan. The following is a brief summary of the key procedural steps undertaken by the Facilitation Team in helping the Chair and Members of the RWPG manage the process of developing the Initially Prepared Plan. The Public Involvement Program, already described, played a major role in shaping a broadly acceptable plan. In addition, the Technical Consultant supported the process of building consensus by providing the necessary tools and technical means for testing alternative approaches. The full facilitation process, then, must be seen as the interplay of all these efforts.

7.1.2    Initial Workshop

After many months of meetings devoted to procedural matters, the RWPG held a workshop (January 1999), organized by the Facilitation and Public Involvement teams. The session helped the planning group begin discussions on substantive issues, revise the goal statement, initially adopt the evaluation criteria presented in Chapter 6 and begin the process of identifying the water options and strategies they wished to have technically evaluated. Regarding the options and strategies, the RWPG had a list of over 100 technical options for meeting water needs in the region. An early major step was to select a limited number for evaluation while committing the group to the principle of remaining as inclusive of strategies as possible. Over the next few months, the selection and redefinition of options and strategies was completed and the evaluation process was begun by the Technical Consultant.

7.1.3    Interviews

In addition to structured discussions during the workshop, the Facilitation Team used another technique to identify the issues and concerns most important to members of the RWPG. Individual interviews were held on a confidential basis in order to encourage members to be as candid as possible about their aims and hopes for the process.  The interviews brought out numerous issues, later summarized in a report, that needed to be addressed if consensus was to be achieved.

7.1.4    Facilitation

The major procedural objectives of the Facilitation Team, as expressed in the Scope of Work, remained central throughout the many months of meetings, workshops and small group sessions that comprised the major portion of the planning process. These were:

1.   To facilitate a good working relationship among the RWPG members in order to lay the foundation for the decision process,

2.   To facilitate the process of identifying and assessing the trade-offs among various water supply options and strategies by the application of selection criteria developed through the public participation process,

3.   To assist the RWPG in using the criteria to formulate as many as six regional water management alternative plans for initial evaluation, then facilitate the process by which those six were reduced to three, then reduced to two,

4.   To provide facilitation, as needed, during the RWPG's decision making process in order to

1.      Ensure that all viewpoints were heard;

2.      Ensure that minority viewpoints were preserved;

3.      Ensure that the decision making process abided by any ground rules established by the RWPG;

4.      Ensure the decision making process was fair and unbiased;

5.   To coordinate closely with the Technical Consultant, the Public Involvement Consultant, the Chairperson and the Administrator in order to harmonize efforts to achieve agreement among the RWPG members on a consensus plan.

The Facilitation Team consulted closely with the Chair and Administrator regarding the handling of issues in each of the monthly meetings, which were presided over by the Chair. Special workshops, small group meetings and individual interviews were used by the Facilitator to make additional progress to ensure movement toward the development of a consensus plan.

7.1.5    Development of Alternatives

The Facilitation Team became especially active in the development of a series of alternative plans. A workshop was held for the purpose of identifying up to six major plan approaches. During the discussions, the Planning Group members coalesced their thinking about alternatives under four of the Evaluation Criteria they had previously adopted. The Group decided to structure alternatives around: 1) Economic – Cost-Effectiveness, 2) Environment, 3) Compatibility – Local Plans and 4) Compatibility – Other Regions. Following the workshop, small working groups developed a procedure for identifying water management strategies that could be applied by the Technical Consultant. They prepared descriptions of each approach, and the RWGP as a whole reviewed and approved each of the four approaches.  The RWGP then assigned the Technical Consultant the task of developing each alternative approach into a regional plan capable of meeting the needs of the water user groups. Each of the four alternatives emphasized the Evaluation Criteria as follows:

·                    The Planning Unit Approach Alternative gave highest emphasis to the criterion of compatibility with local water plans.

·                    The Environment and Conservation Alternative emphasized nine elements, each of which was used to evaluate the list of available options and strategies. The nine elements, which differed from the sub-headings under the Environment Criteria previously adopted, were as follows:

·                    Endangered Species

·                    Unique Stream Segments

·                    Bays & Estuaries

·                    Instream Flows

·                    Riparian Forests

·                    Cultural Resources

·                    Size of Habitat Disturbance

·                    Water Quality

·                    Sustainability (Level of Groundwater Decline)

·                    The EREPA Alternative (the acronym stood for Economic, Reliability, Environmental and Public Acceptance – four of the Evaluation Criteria) came to emphasize cost per acre-foot of water produced by the options.

·                    The Inter-Regional Cooperation Alternative emphasized compatibility with other regions by developing a set of water supply options that necessitated joint planning with Corpus Christi and the Coastal Bend Region.

The Evaluation Criteria thus played an important role in shaping, and later evaluating, the alternatives, but were not applied to component management strategies. The purpose of the Evaluation Criteria was to guide the RWPG members in their assessment of each alternative as a whole. These Criteria were not expected to be applied by the Technical Consultant in the same way as the criteria detailed in the TWDB rules for preparation of regional water plans (though there is some overlap of the two sets of criteria). Rather the Technical Consultant responded to specific direction from the RWPG to apply those Evaluation Criteria that were relevant to each alternative. The RWPG members themselves applied the Evaluation Criteria during their deliberations in a subjective manner and recorded their rating of each alternative under each of these criteria by using a rating scale developed for this purpose, as noted below.

Following development of these alternatives, another approach, known as the Edwards Aquifer Recharge and Recirculation Alternative, was added, based on the ideas submitted by a member of the public.

Planning Group members suggested many additional ideas as the basis for alternatives, but it was the five listed above that moved on to the next stage of technical evaluation. When it became clear that some of the alternatives did not provide sufficient water from options and strategies chosen solely  according to the rules and priorities of each plan, the RWPG authorized the Technical Consultant to add further options to meet water user group requirements. Thus, the alternatives departed, to some extent, from the original concept underlying each one.

In addition to reviewing the technical evaluations, the RWPG members individually used the Evaluation Criteria to assess the five alternative plans and also considered numerous public comments, RWPG member concerns and technical issues in moving to the next step of narrowing the number of alternatives.

7.1.6    Selection of Initially Prepared Plan

The process of selecting a plan originally envisioned by the Planning Group and incorporated into the Scope of Work for consultants, prepared in 1998, called for first developing as many as six alternative plans, then narrowing these down to as many as three for further evaluation, then two and finally arriving at agreement on the regional plan itself. After completing the first step in this process by the end of June 2000, the RWPG members felt there was no time to complete the remaining steps as originally contemplated. Instead of fashioning three alternatives based on the input to that point, the members chose to use a "single-text" procedure in the interest of meeting the deadline for preparation of the Initially Prepared Regional Water Plan. That procedure consists of focusing on a single plan and making revisions to it until consensus has been achieved.

By the time the RWPG members developed the single text, known as the "Hybrid Alternative", they had become familiar with extensive information from the public and from various county, municipal and other local officials about concerns relating to particular management strategies and the major alternatives. They had developed from this input a keen sense of which strategies and alternatives would gain the widest acceptance across the region. The Evaluation Criteria of economic impact relating to cost-effectiveness, environment, water quality, reliability, efficiency and flexibility all played a role in defining the "hybrid alternative." The key Evaluation Criteria at this stage, however, seemed to be economic impact (relating to minimizing negative socio-economic impacts), efficiency (relating to promoting conservation and conjunctive use), fairness (relating to efficient use in a water-importing area and distribution of costs and benefits), feasibility (relating to public acceptance and political feasibility, in particular) and compatibility (with local and regional plans as well as with property rights).

At a special workshop, the Planning Group members began with a list of water supply options and strategies that had appeared in each of the five alternatives reviewed up to that point. They then added options that had either generated near unanimous support or which had little in the way of opposition or technical obstacles. In addition, they included strategies that were promising for the long-term but which needed further study. The RWPG built consensus on this alternative relatively quickly because of the extensive technical evaluations and comparative discussions that had preceded this phase of the process. The group did not require or pursue step-by-step documentation of the detailed basis for agreement on the part of each member or the specific way in which each arrived at the decision that he or she decided that the hybrid alternative was acceptable. While the RWPG was considering and refining this alternative, two river authorities in adjoining planning regions proposed new options, one of which was added to the emerging regional water plan. The Technical Consultant reviewed the new plan, and the RWPG made a number of changes, culminating in acceptance of the Initially Prepared Regional Water Plan on August 17, 2000.

7.2       Public Participation

7.2.1    Introduction

Moorhouse Associates, Inc. was contracted by the SCTRWPG to provide Public Participation professional services.  Moorhouse Associates representatives attended all RWPG meetings and staff work group meetings conducted during the planning process.  The public participation process for the SCTRWPG was designed to facilitate information out to the public about the work of the planning group throughout the process, and to provide feedback from the public at key decision points.

7.2.2    Phase I Public Participation

The first phase of the public participation contract consisted of project planning and involved working with the planning group members, technical contractor, and the facilitator to define public participation roles and objectives.  It also involved identifying the major planning components and issues for the region, as well as reviewing past public participation efforts.  The Phase I Public Participation Report analyzes past public participation efforts and provides baseline information for performing the public participation process for the south Central Texas Regional Water Planning Group.

At the SCTRWPG workshop held in San Antonio on January 29-30, 1999, the planning group adopted a principle of public participation that was the guiding principle for the public participation process.  Also at the workshop the group adopted the initial criteria for evaluation of water supply options.  The criteria adopted by the planning group were those developed during the Trans Texas process.  Future public participation and planning group input was designed to further define and/or weight these criteria for use in developing the regional water plan. The criteria, as adopted by the SCTRWPG, are listed in Section 6.5 of this volume.

Principle of Public Participation

The role of the Regional Water Planning Group is to create and implement a public participation plan that provides for meaningful participation in the development of an acceptable regional water plan.  The public participation efforts should foster a relationship of mutual trust, honesty, respect, and interaction between the Planning Group and the public.

7.2.3    Phase II Public Participation

As part of the second phase of the public participation process, Moorhouse Associates, Inc. conducted two surveys for the SCTRWPG. The first survey asked the RWPG members to give their input as to how they would like to see the public participation process occur, how to best reach the group or groups that they represent on the committee, and how they would like to participate in the public participation process.  The second survey was conducted to receive input from the public during the early planning stages of water option review and criteria development. The target audience for the survey was persons or groups that were already familiar with water issues in the region. The final task of the Phase II was to develop the scope of work for the Phase III or implementation phase of the Public Participation process.

7.2.3.1     Regional Water Planning Group Member Survey

Regional Water Planning Group members, as well as non-voting members, were surveyed in February 1999 regarding their perceptions of previous public participation efforts, effective participation and informational strategies, roles and responsibilities of group members and contractors, and key messages.  A total of 24 responses were received, representing 19  voting and 5 non-voting members.  Survey result highlights are presented in the Phase II Public Participation RWPG Survey and Targeted Audience Survey Results Report (May 6, 1999).

7.2.3.2     Targeted Audience Survey

The mailing list for the survey was compiled from several mailing lists provided by various organizations, associations, river authorities, clubs and interested parties. The survey is not a statistically valid random representation of the general public in the region. It is a targeted or focused survey of persons or groups active with water issues in the region.

The goal of the survey was to gather public input for guidance in three areas:

1.   Rate water supply options.

2.   Further develop evaluation criteria for water supply options.

3.   Identify new water supply options.

The targeted audience public survey was sent to nine thousand four hundred twenty six (9,426) persons and seven hundred twenty (720) or eight percent (7.64%) of the surveys were returned. The responses (Graph 1) indicated that all the evaluation criteria used by the planning group were considered to be extremely or very important by respondents. The water supply options were rated from extremely to somewhat important with conservation widely supported by all groups. The Phase II Public Participation RWPG Survey and Targeted Audience Survey Results Report (May 6, 1999) is available for viewing on the website.

7.2.4    Phase III Public Participation

The Phase III plan for public participation was developed with the goals of maximizing public involvement throughout the development of the regional water plan, and facilitating broad-based public understanding and support of the final plan. 

7.2.4.1     Public Information Dialogue Presentations and Questions from the Public

Public Information was provided throughout the region in the form of Public Information Dialogue (PID) meetings. A presentation about the regional water planning process was made at total of seventy-one meetings. Approximately 3,634 persons attended these meetings, and 938 feedback cards were received from persons attending the meetings.

SCTRWPG meetings were well attended by the public and information was also gathered from input cards at the planning group meetings. A total of 286 input cards were collected from the SCTRWPG meetings.

Questions from the public were collected and distributed with answers at the monthly meetings. The individuals submitting the questions received a written mailed response to their inquiry. A total of 196 questions and answers were generated from July 1999 to July of 2000. Questions and Answers from the Public are available on the website.

7.2.4.2     Focus Group Report I

Focus groups were used during key decision points. The focus groups were established by contacting the County Judges in each of the 21 counties of the region. Each Judge was offered an individual briefing by a planning group member and a representative from Moorhouse Associates, Inc. The briefing provided an overview of the planning process, a discussion of the issues and a review of the upcoming schedule. The judges were asked to provide a list of persons from their county using the list of eleven interest categories represented on the planning groups. These persons were then invited to participate in a focus group that provided feedback on the criteria to the RWPG. Four hundred and one persons were invited to participate and two hundred thirty six were able to participate. The input was presented to the RWPG at a workshop October 12, 1999. The Phase III Public Participation Twenty-One County focus Group Report (October 1999) is available on the website.

7.2.4.3     Option Specific Public Input Sheets

For the workshops where the planning group was considering options to include in the alternative plans or the hybrid draft, option specific public participation input sheets were generated. These sheets summarized the Targeted Audience Survey Results, Focus Group input, public comments and concerns about the option, and any newspaper coverage relative to the option. These option specific input sheets were first presented at the workshop on January 27, 2000 and were updated for those options included in the five alternative plans and presented at the workshop on June 13, 2000.

7.2.4.4     Focus Group Report II

A second group of Focus Groups was conducted in July of 2000. The original lists provided by the County Judges were updated and supplemented by suggestions from area legislators. The legislators were provided the opportunity of a briefing and update on the plan process. They were then asked to suggest any additional names for focus group participation. Nine additional Focus Groups were included in the second round. Eight of these were Bexar County specific, one was for Trinity Aquifer representatives, and one was for the Bays and Estuaries or downstream interests. This second round of focus groups reviewed the ‘Hybrid Draft Alternative Plan’ as of July 2000.  Three hundred and ninety nine persons participated in the second round of Focus Groups. A presentation of the results for the second round of focus groups was made at the August 3, 2000 SCTRWPG meeting. The Public Participation Focus Group II Report, Hybrid Draft Plan as of July 2000 (August 2000) is available on the website.

Website: www.watershedexperience.com

The website was presented for review at the September 14, 1999 SCTRWPG meeting. The website provided access to the technical documents, the calendar of events, meeting minutes, and several interactive map activities relative to the options under consideration. The website activity report was presented at each monthly SCTRWPG meeting. The busiest day (2633 hits) on the website was April 17, 2000. This was the time when alternative plan information was becoming available on the website.   The total hits to the website from September 1999 to July 2000 were 275,902 and the number of users of the site during that time is estimated to be 8,167.

7.2.4.5     Planning Group Literature

The Phase III plan included the development of a general brochure for use during the public process.  The brochure was an introductory piece that explained the region, the process, the schedule, and provided information on how to participate in the process.  These brochures were distributed at all public information dialogue meetings, RWPG meetings and included in all mail-outs.  The brochure was also available in Spanish.

A newspaper insert detailing the water planning process and the draft water plan was also developed for distribution to a mass audience.  The insert was for area papers and included a circulation of about 550,000.  The insert was also designed for use during the public hearing process in September 2000.

7.2.4.6     Media Relations and Monitoring

Press releases were distributed prior to every SCTRWPG meeting and staff work group meeting.  Press releases were also issued about planning group decisions and studies as they became available.  Media coverage of water issues was monitored through clippings.  Coverage of RWPG business was more intense in areas where potential reservoir sites were under evaluation.  The April 2000 press release outlining the five alternative plans was covered in twenty-two clippings throughout the region.

7.2.4.7         Public Hearings on Initially Prepared Regional Water Plan

The Initially Prepared Plan (IPP) was available for public review on August 25, 2000.  Public hearings to receive comments on the IPP were scheduled in Victoria, Uvalde and San Antonio on September 25, 26 and 27, 2000 respectively. During the week prior to the public hearings an eight-page tabloid summarizing the IPP was inserted into newspapers throughout the region for a total circulation of 550,000.  Approximately 650 persons attended the public hearings and oral comments were recorded by a court reporter that provided a certified transcript of the comments. The official public comment period ended on October 6, 2000. During the comment period the planning group received 270 written comments and heard 97 oral presentations at the public hearings.

Each written comment was entered into a database, assigned a number and reviewed individually. The transcripts from the public hearings were provided on computer disk and these oral comments were also integrated into the database format, assigned a number and reviewed individually. During the review process, thirty-eight common comment categories were identified. The list of categories is presented in Table 7-1, however, the categories are not presented in any particular order.  Whenever a commenter addressed one of the issue categories it was indicated in the database entry for that comment. Many of the comments covered more than one category; so multiple issue categories were often assigned to one document or comment.  Table 7-1 also indicates the number of comments addressing each category by source.

The planning group decided to develop responses to the comments by category groups. A set of comment documents sorted by category was provided to each planning group member for review. Through a series of workshops, the planning group developed responses by category for each comment received. HDR Engineering reviewed specific technical questions discussed in the comments and prepared draft responses for review by the planning group. The planning group responses to the comments are presented in Section 7.2.4.8, below, changes were made to the IPP in response to the public comments. The RWPG listened to the public, and the evidence is clear from the number of changes incorporated in the Final Regional Water Plan.  Many communities, agencies and interest groups had a decisive role in shaping the development of the South Central Texas Regional Water Plan.

 

7.2.4.8         Regional Planning Group Responses to TWDB and Public Comments on Initially Prepared Regional Water Plan

7.2.4.8.1    TWDB Comments and RWPG Responses

TWDB Preliminary Staff Comments, Letter 1, October 11, 2000

 

Section I.  Comments that have to be satisfactorily addressed in order to meet Statute, Texas Water Development Board Rules and the Regional Water Planning Contract.

 

5.       Texas Water Code Section 16.053(e)(3)(A) and 31 TAC §357.5(e)(7), require that for each source of water supply in the regional water planning area designated in accordance with 31 TAC §357.7(a)(1), the regional water plan shall identify: (A) factors specific to each source of water supply to be considered in determining whether to initiate a drought response, and (B) actions to be taken as part of the response.  This information could not be located in the Initially prepared Plan (IPP) and must be clarified to explicitly address the referenced Statute and rule.

Response: Sources of ground and surface water are listed and described in Section 3 of Volume I.  Subsection 3.3 was added to Section 3 in which items A and B above are addressed.  EAA’s draft “Critical Period Management Rules” are  included for the Edwards Aquifer.  For other sources, the Emergency Demand Management Plans that have been summarized in Volume 1, Section 1 are referenced.

 

6.       The supply available from Canyon Lake was not consistently reported in the following tables: IPP Volume I, Table 4-23, 52,350 ac-ft; Exhibit-B Table 6, 64,070 ac-ft.  Additionally, IPP Volume I, Table 3-2, reports a permitted volume of 50,000 ac-ft.   Please address the differences that relate to available supply and report the information in a manner consistent with 31 TAC §357.7(a)(3), regarding evaluation of adequacy of current water supplies available to the regional water planning area for use during drought of record.

Response: Volume I, Table 4-23 shows 50,000 acft/yr for GBRA from Canyon Lake.  The “additional” Canyon amount for CRWA is part of the 50,000 acft/yr and is noted accordingly.  In Exhibit B, Table 6, Canyon supplies shown for New Braunfels, San Marcos, and CRWA are part of the 50,000 acft/yr for GBRA and are  noted accordingly.  Presentation in this manner is necessary to accurately portray supplies available to each Major Provider.

 

7.       The surface water supply available from direct reuse was not consistently reported in the following tables: IPP Volume I, Page 3-11, item E, and IPP Volume I, Table 4-2, 24,941 ac-ft; Exhibit-B Table 4, 28,877 ac-ft.  Please address these differences and report the information in a manner consistent with 31 TAC §357.7(a)(3), regarding evaluation of adequacy of current water supplies available to the regional water planning area for use during drought of record.

Response: The 24,941 ac-ft is listed both in IPP Volume I Table 4-2 and Exhibit B Table 4 for Bexar County.  An additional 3,936 acft/yr is listed in IPP Volume I, Table 4-12 and Exhibit B Table 4 for Hays County, bringing the total to the 28,877 ac-ft mentioned above. These are obtained from wastewater and are considered to be dependable during drought, as tabulated.  The 3,939 acft/yr for steam-electric use in Hays County is noted in Section 3.4 (Section 3.3 in IPP).

 

8.       Volume I, Section 3.1.8, Groundwater Availability in the South Central Texas Region, Page 3-4, includes a footnote regarding an agreement endorsed by staff of the TWDB relative to the available supply from the Edwards aquifer.  To more adequately reflect the implication to the planning effort of the referred agreement, please expand and incorporate this reference in the main body of the report to better inform the reader as to the process resulting in the agreed supply volume and the conditions associated with the agreement regarding protection of endangered species.

 

Response:  The following language is included in Volume I, (Page 3-4 of IPP) at the point in the text where footnote No. 1 previously appeared. 

 

“For planning purposes, an estimate of 340,000 acft/yr of available supply during a drought of record from the Edwards Aquifer was agreed upon by the South Central Texas Regional Water Planning Group and the staff of the Texas Water Development Board.  This quantity was adopted as a placeholder number until the EAA completes and acquires approval from the U.S. Fish and Wildlife Service for a Habitat Conservation Plan (HCP).  TWDB staff, in a letter to Greg Ellis, dated November 16, 1999, agreed to accept water availability from the Edwards Aquifer as 340,000 acft/yr after 2012 in the Regional Water Plan if it includes actions to be taken to ensure that the required level of protection to the endangered species at San Marcos and Comal Springs will be maintained during a drought of record”. 

 

The previous footnote was replaced with the new footnote No. 1 as stated above.

 

9.       IPP Volume I, Page 3-11 through 3-15, Methodology to Calculate the Water Supplies Available to the South Central Texas Region and Methodology for Calculating Water Supplies Available for Water User Groups, and Tables 4-1 through 4-23.  The report states that surface water availability for permits within the Nueces, Guadalupe and San Antonio River Basins were obtained from the Texas Natural Resource Conservation Commission (TNRCC) Water Availability Model (WAM) Runs.  Table 4-22 provides the river basin summaries comparing water demand and supply within each basin.  However, the report lacks a link to allow a correlation between the surface water availability for permits and the contents of Table 4-1 to 4-22 and with the tables required as per Exhibit B of the contract.  In order to allow for an independent verification of these facts and to assess compliance with 31 TAC §357.7(a)(3), please:

 

a.       Clarify which one of the various runs of the TNRCC WAM was used for this report.

 

Response: For the Nueces, Run 9.  For the Guadalupe – San Antonio, Run 10.  Run 10 is a special run that provides information regarding water availability subject to assumptions adopted by the SCTRWPG.  The technical assumptions and conditions used in Run 10 are stated in Section 3.4 (formerly 3.3), Volume I.

 

b.       Provide a list of major water right holders by river basins within the planning area, along with the permit number and the minimum annual supply during the drought of record from results of WAM.  Please refer to Section 3.3.4, Required Documentation, of the TWDB technical memorandum for Tables 3 & 4, dated October 4, 1999;

 

Response: This list is included in  Appendix C –Major Water Right Holders by River Basin.

 

c.       Provide a list of the major reservoirs, supply available from these reservoirs, and the water rights associated with these reservoirs including permit numbers, for each of the river basins within the planning area.

 

Response: Table 3-2, Page 3-7 of Volume I shows the list of reservoirs and permitted water rights values for each.  The supplies available, as per Run 10 mentioned in 5.a above are tabulated in the Tables 4-1 through 4-22, and Exhibit B Table 4, as applicable.  The list was added to Volume I, Section 3.

 

d.       For review purposes, please segregate the supply by source category in Table 4-22 to allow verification of these values with Exhibit B Table 4.

 

Response: Table 4-22 is a River Basin by source category summary for all counties and parts of counties of the region.  TWDB is referred to Tables 4-2  through 4-21 where the sources of supply for the drought of record are shown, together with the name of the source.  The sources are further tabulated by TWDB’s numeric codes in Exhibit B, Table 4. 

 

6.   31 TAC §357.5(e)(1) requires that in developing the regional water plan, the regional water planning groups shall "evaluate alternative water management strategies for effect on environmental water needs including effect on instream flows and bays and estuaries using environmental information resulting from site-specific studies, or, in the absence of such information, using state environmental planning criteria adopted by the board for inclusion in the state water plan after coordinating with staff of Texas Natural Resource Conservation Commission and Texas Parks and Wildlife Department."  In order to verify compliance with the referenced rule, please explain how this requirement has been addressed in your evaluation of alternative water management strategies and provide the following information on the evaluation of each alternative water management strategy and the recommended regional water plan:

 

a.       List all diversion points in the WAM model where a decision is required for application of the environmental flow criteria.

 

Response:  This information is included in Volume III, Appendix F entitled Application of Consensus Environmental Criteria.

 

b.       For each one of the diversion points identified in item a., please show the median, 25%tile, and 7Q2 flows in cfs.  The units for the tables and graphs presented in IPP Volume I, Figures 5.2-40 through 43 are not consistent.

 

Response:  Data are included in Volume III, Appendix F mentioned in Comment 6.a above.

For Volume I, Figures 5.2-40- through 42, which are for the San Antonio and Guadalupe Basins, units on the vertical axes are in acft/mo.  This is because the computer modeling for these basins was done in monthly time steps.  For Figure 5.2-43, which is for the Colorado River Basin, the vertical axis units are in cfs, and is because the computer modeling was done in daily time steps.

 

c.       In order to facilitate review of this information with regards to the environmental flow requirements, please provide them in cfs as required in the Regional Water Planning Contract, Exhibit B, Section 1.3.1.

 

Response:  Data are included in Volume III, Appendix F as mentioned in Comment 6.a above.

 

7.       31 TAC §357.5 (d) requires that in developing regional water plans, regional water planning groups shall use state population and water demand projections contained in the state water plan or those adopted by the TWDB.  On August 13, 1998 the South Central Texas Regional Water Planing Group (SCT RWPG) approved a scope of work and budget to conduct a review of the population and water demand projections for the planning region to correct those projection judged to be in error.  On November 20, 1998, the SCT RWPG submitted a request for revisions of population and water demand projections to the TWDB.  On January 21, 1999 the TWDB considered and approved a recommendation from TWDB staff that all revisions requested by the SCT RWPG be approved.  Appendix A to these comments compares the information presented in the IPP with the TWDB approved projections.  Please correct the discrepancies noted in Appendix A in order to comply with the referenced rule.

 

Response: Subsequent to the actions described above,  the Technical Consultant was presented information by GBRA and the Schertz-Seguin consultant that 3 new steam-electric power plants were being constructed in the region—2 in Guadalupe County and 1 in Hays County.  The Technical Consultant obtained data about the water demands of each, conferred with representatives of TWDB (none of whom are still with TWDB), and proceeded to include these demands in the water demand tables of the plan, and in Exhibit B, Table 4.  In addition, the Technical Consultant remembered that the TWDB irrigation water demands are in terms of quantities of water on the farms in the fields being irrigated.  For irrigation using groundwater sources, this is the appropriate and correct quantity, because in most cases the water is pumped from beneath the acres being irrigated, and does not have to be transported any distance to the points of use.  In the case of irrigation using surface water, this may not be the correct quantity to use as the irrigation demand, because water diverted from streams usually must be transported to the fields to be distributed.  This is the case in parts of Region L, where surface water is conveyed to the fields using unlined canals.  Therefore the Technical Consultant obtained data from the TWDB with which to compute canal losses, and added these quantities to the irrigation demands where applicable (Calhoun, Medina, Zavala, and Dimmit Counties).  

 

The Technical Consultant did not inform the SCTRWPG of the actions described above, and of course the SCTRWPG did not know that a formal, written request of the TWDB to get these changes approved was required.  A letter was prepared requesting the changes mentioned above.  At its regular meeting on November 2, 2000, the SCTRWPG approved the action to make the request.

 

8.       In Exhibit-B Tables 1 and 2, the outside-city population and associated municipal water demands for the City of Schertz are noted under the water user group (WUG) number for the City of Schertz, #120808000.  This is incorrect.  The outside-city population and related demands should be included in the "county-other" category under WUG # 120996015.  Please correct the error to facilitate accurate reporting and verification of compliance with 31 TAC §357.7 (a)(2).

           

Response: The suggested change was made.

 

9.       31 TAC §357.7(4) requires that the social and economic impact of not meeting regional water supply needs be evaluated by the Region.  The information is in the IPP; however, the corrections to the water demand projections (Comment #7) will cause changes in the projected water needs of the Region (IPP Volume I, Sections 4.1 and 4.2, Tables 4-1 through 4-9).  The revised needs will require the update of Section 4.3 "Social and Economic Impacts of Failure to Meet Projected Water Needs" (Tables 4-24 through 4-28), an update of the "Exhibit B" electronic Tables 9 and 10, and a reevaluation of the impacts of unmet water needs by TWDB staff.  In addition to the noted corrections, the Projected Water Needs for a significant number of Water User Groups in Tables 4-24 through 4-28 (socio-economic impacts) are NOT CONSISTENT with shortages listed earlier in the IPP (Tables 4-1 through 4-21) or with shortages provided to TWDB for the preparation of the socio-economic impact analysis.  Please revise the socio-economic tables and Exhibit B, Tables 9 and 10. to ensure that water shortages are reported in a consistent manner throughout the document and in the TWDB analysis of socio-economic impacts.

 

            Response: The necessary changes were forwarded to TWDB on or about November 1, 2000.  Upon receipt of the revised computations, Volume 1, Tables 4-24 through 4-28 were revised, as appropriate.

 

Section II.  Comments/Suggestions for Improvements to the Regional Water Plan

 

1.       31 TAC §357.7(a)(1) requires that the regional water plan include a description of natural resources.  Please consider the following suggestions to improve the plan's description of the natural resources in the region, specifically as related to Volume 1, Section 1.2.4.2, Wildlife Resources:

 

a. The referenced section includes a description of the rare Texas Salamander, Eurycea neotenes, which is not listed as an Edwards aquifer dependent species in Volume III, Appendix E-1, Endangered Species Related to the Edwards.  For completeness, the species should also be included in Appendix E-1.

 

Response: The species is listed, as suggested.

 

b. Volume 1, Section 1.2.4.2, Wildlife Resources, discusses only one of 23 Edwards aquifer dependent species.  This section would be more informative and benefit from inclusion of a more comprehensive discussion of the 23 species of listed in Volume III, Appendix E-1.

 

Response: Discussion in the SWG meeting on October 24 raised the question of what value the discussion is to development of the regional water plan, and especially since the IPP has been developed with only one species having been discussed.  Therefore, the referenced discussion was removed.

 

c.       It might also be appropriate to point out which species are dependent on San Marcos and Comal springs, versus those that are dependent on deeper aquatic environments of the Edwards aquifer.  The later group of species may not be as sensitive to water planning issues.

 

Response: Inasmuch as environmental laws and regulations have declared that the flows of these springs be maintained at levels satisfactory to protect the habitats of the species of the springs, and water planning has been directed to proceed accordingly, the SCTRWPG questions this comment, and has decided to forgo the opportunity to engage in the suggested exercise.

 

2.       31 TAC §357.7 (a) (1) requires that the regional water plan include a description of any identified threats to the natural resources of the regional water planning area due to water quality problems or water quantity problems related to water supply.  Even though there are various related references throughout the text in the report, the index to Volume I of the IPP directs the reader to Section 1.9, Volume I, Threats to Agricultural and Natural Resources, for information on this particular requirement.  Please consider enhancing this section with more specific information related to threats to natural resources to improve the clarity of the report.  Also note that, 31 TAC §375.7(a)(7)(D) requires that evaluations of water management strategies include impacts of water management strategies on threats to agricultural and natural resources of the regional water planning area.

 

Response:  Cross-references have been added in Section 1.9 to the other places in the report where the subject is addressed specifically.

 

3.       Volume III, Appendix D, entitled Endangered Species by County, includes threatened and endangered species by county.  Please consider changing the title to reflect the inclusion of threatened species.  Also, there is apparently no reference in the text of the IPP to this appendix.  It is recommended that information about threatened and endangered species in the region be referenced to Appendix D.  Those endangered species dependent on the Edwards aquifer would be more appropriately located in Appendix E, Endangered Species Related to Edwards Aquifer.

 

Response: Appendix D was renamed, “Threatened, Endangered, and Rare Species by County.” Each of the county tables already bears this title. A reference to Appendices D and E has been added to Volume I in Section 5.2.5.1.