SRE-WSC Participation in Comprehensive Texas Water Planning Process
Message from Stephen Greenberg, Attorney at Law
Submitted on behalf of Skyline Ranch Estates Water Supply Corporation (SRE-WSC)
SRE-WSC comment on Texas Water Development Board (TWDB) Region L Water Plan:
http://skylineranch.org/content/filemgr/files/wsc_comment_regl_ipp_2010.pdf [pdf, 86 KB]
Texas Water Development Board (TWDB) Region L Water Plan: history
In June 1997, the Governor of Texas signed into law Senate Bill 1 (SB 1), which included comprehensive water legislation enacted by the 75th Texas Legislature. SB 1 created a regional water planning process and designated the Texas Water Development Board (TWDB) as the lead agency for coordinating the regional water planning process. The overriding purpose of the regional water planning process is to ensure that the water needs of all Texans are met as Texas enters the 21st century and experiences the population growth projected for the 21st century.
The overall goal of SB 1 was to “develop regional and state water plans that will provide for the orderly development, management, and conservation of water resources, and preparation for and response to drought conditions in order that sufficient water will be available at a reasonable cost to ensure public health, safety, and welfare further economic development, and protect the agricultural and natural resources of the planning area.” SB 1 designated 11 interest groups to serve as members of Regional Water Planning Groups (RWPG) to prepare regional water plans for their respective areas. These plans are intended to map out how to conserve water supplies, meet future water supply needs and respond to future droughts in the planning areas.
In 1998, the Texas Water Development Board adopted rules for state and regional water planning and grant assistance, designating 16 regional water planning areas to implement state and regional water planning aspects of SB 1. The original state water plan was created and adopted in 2002 through the regional water planning process, and SB 1 called for the plan to be updated every 5 years. The original water plan was replaced in 2007 by successive plan documents, drafted again through the regional water planning process. The current Texas Water Plan is the one that was adopted in 2007.
Each Regional Water Planning Group remains responsible for preparing and adopting an updated regional water plan for their area. Texas Regional Water Planning Groups are working on the next update of the comprehensive Texas Water Plan, which is in the drafting stages in 2010 – the efforts of which are intended to complete the next comprehensive water plan in time for adoption in 2011, to replace the 2007 Texas Water Plan.
The South Central Texas Regional Water Planning Area (Region L) is one of the 16 regional water planning areas designated by TWDB, the lead state agency in the water planning process. Region L contains the following counties: Atascosa, Bexar, Caldwell, Calhoun, Comal, Dewitt, Dimmit, Frio, Goliad, Gonzales, Guadalupe, Karnes, Kendall, LaSalle, Medina, Refugio, Uvalde, Victoria, Wilson, Zavala, and the southern part of Hays County that lies within the Guadalupe-Blanco River watershed. (The northern part of Hays County lying within the Colorado River watershed is included in Region K, the Lower Colorado Regional Water Planning Group).
In March 2010, Region L issued its 2010 Initially Prepared Plan (IPP) and requested the submission of responsive public comments. The June 13, 2010 letter [pdf, 86 KB] was submitted to Region L on behalf of the Skyline Ranch Estates Water Supply Corporation, in response to Region L’s request for comments on the Region L March 2010 IPP.
SRE-WSC comment on Region L IPP: executive summary
Following are the points we tried to make in our comment:
- Although the draft plan purports to comprehensively address future water use by all water users in Region L, there is no consideration given to water used by rural water users such as the residents of Skyline Ranch Estates. Instead, the only water users in the Wimberley Valley whose future water needs are addressed are the customers of the Wimberley Water Supply Corporation and Woodcreek Utilities, Inc. (Aqua Texas), the water utilities which serve fewer than half the residents of the Wimberley Valley.
- Although the plan proposes a water project to increase the water supplies of the Wimberley Water Supply Corporation and Woodcreek Utilities, Inc. (Aqua Texas), on account of inadequacies of the Trinity Aquifer which provides their water, no projects are proposed to supplement other water users who also draw their water from the Trinity Aquifer – such as the customers of the Skyline Ranch Estates Water Supply Corporation. We suggested that additional supplies to meet future water needs of SRE-WSC and other nearby small water systems be included in that project.
- With no reasoned discussion, the plan dismisses any need for possible cross-basin water transfers into the Blanco-Guadalupe River basin from other watersheds. Our comment points out that the LCRA water pipeline that runs south of Dripping Springs is probably the closest possible alternative water supply for the SRE-WSC – even closer than Canyon Lake and San Marcos, the alternative sources to be used for transferring additional water to the Wimberley Water Supply Corporation and Woodcreek Utilities, Inc. (Aqua Texas) in the proposed Wimberley Water Project – and suggested that LCRA pipeline be considered as an alternative water source that would involve a cross-basin transfer.