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Water & the Edwards Aquifer
Water is life - use it, but always use it wisely

Vista Ridge plans need more scrutiny
October, 2014

While SAWS rushes to sign the Vista Ridge Water Project, a $3.4 billion project to pipe and pump 50,000 acre feet of water a year from Burleson County, and city leaders and the media line up in support, there is a critical need to pause and review the potential downsides of Vista Ridge.

What you need to know about Vista Ridge

Visit our Clearinghouse for Vista Ridge Information webpage, where you can find news articles about the deal, comments and analyses about the proposal, and technical studies.

The project’s carbon footprint should be a consideration, since San Antonio is committed to the Mission Verde policy and becoming a Top Ten Green City.  San Antonio has not estimated nor has a plan to address our carbon footprint.  Vista Ridge plans will move up to 50,000 acre feet of heavy water uphill and over 142 miles for 30-plus years that will require prodigious energy and produce un-quantified carbon emissions.  How can San Antonio leaders justify this added climate burden and that from the resulting development and population growth it enables without knowing the impacts?

The project claims on water availability also challenge us to question assumptions, risks, and fairness. The huge Carrizo-Wilcox aquifer arcs across the state from the Rio Grande to the NE corner border, its water moving within and between some of the aquifers above and below (cross-formational flow). This means impacts in one area may affect other areas.  The Carrizo Sand and Simsboro Sand formations are the proposed sources of Vista Ridge water. They can provide base flow to springs and rivers—in this area to the Brazos and Colorado Rivers—from surface outcroppings, which also receive recharge.  The ground water is used for mining, agriculture, livestock, rural homes, manufacturing, power and municipalities. A key 2002 Texas groundwater recharge study suggests that in this segment, the major rivers will continue to receive groundwater discharge even with certain assumptions about increased pumping and drought conditions. Are those assumptions justifiable, and what climate change data was used, if any? Any reductions in river base-flow and the magnitude should be answered before large projects such as Vista Ridge are allowed to proceed, as should impacts on existing wells and other uses that will need addressing.

It is well known that surface and groundwater is over-allocated in Texas, so as we get hotter and drier, growth advances and demand rises, therefore the risk of cutbacks will grow.  The Post Oak Savanah Groundwater District’s (POSGD) Director Westbrook  claims they  have 125,699 acre-feet annually permitted, with average production in the past five years at 13,080 acre-feet, with a peak of 20,296 in 2011, but  its modeled available groundwater is only 61,020 acre-feet annually. A 2005 ground water assessment  (Wade, 2005) indicated that the recharge in Burleson County’s segment of the POSGD Carrizo Wilcox aquifer averages just 13,000 acre feet per year—only about one fourth of the 50,000 acre feet Vista Ridge promises to deliver to SAWS from Burleson County. Where will the other 3/4ths come from? It will flow in from neighboring properties, unless prevented by equally heavy pumping in neighboring districts. This and other studies commissioned by the Texas Water Development Board, show the major impact will be the permanent and significant drawdown of aquifer levels. The prospect is already spurring a water war. A busload of citizens from the Burleson County area plans to descend on our city hall under a campaign with the battle cry “Remember the Ogallala”.

To be sustainable, aquifer drawdown should be no greater than recharge.  Yet Texas policy is “managed drawdown,” meaning we are allowing our aquifers to drop to support ever greater populations, thus putting more people at higher risk.  Wade’s 2005 study reported that by 2050 the draw down in the Simsboro aquifer  will be more than 200 feet, with significant drawdown mapped in most areas of that and the Carrizo Sands formation.  Other modelling requested of the Texas Water Development Board in 2003  by the POSWD showed dramatically greater drops in the Simsboro by 2030, based on a possible scenario that pumps 20% less than the amount permitted there.  The  2002 Texas groundwater recharge study estimated the highest recharge rate in the Carrizo-Wilcox aquifer to be 5.8 inches per year, with much less in some areas. We must be assured that current consensus on Texas climate change precipitation and evaporation projections be added to modeling and that we apply precaution to the large availability discrepancies that such an inexact science produces.

SAWS estimates Vista Ridge costs will add 16% to rates over 5 years. We must question this figure and the assumptions it is based on. If VR water will be one fifth SAWS’ supply at about $2200 an acre foot—about 4 times the highest cost water of Edwards Aquifer—which is 90% of our supply now—then  a quick calculation shows this will raise acre-foot costs by about 60%. SAWS promises a special “lifeline” rate for certain low-income clients, but other low and middle income sectors, suffering under stagnant income and rising inflation, will be hurt too. Vista Ridge advocates also claim SAWS can mitigate this rate hike by selling the extra water early on, but who would buy this expensive water as anything but for temporary, high value or stop gap purposes, as buyers can lose access to the water and might not have it when it is most needed—in drought or as necessary supply for a now larger, dependent population.

$3.4 billion, or $110 million per year (or whatever the final bill), will largely flow out of the local economy toward a foreign company, its sub-contractors,  and Burleson County landowners, costing San Antonians and our local economy.  What might San Antonio accomplish if that money were redirected here toward sustainable development?

Business interests, led by the Chamber of Commerce, insist we need this water, in addition to other desalinated and fresh water projects, to keep and attract jobs to meet the growing population, and that we need minimal government regulation and all benefit from growth these expanded utilities foster. No one has challenged these assertions. City, county, and utility leaders appear in thrall to this claim and an inevitable, desirable, and manageable high population growth, estimated at about 20,000 per year. Continuing to engineer our way around natural limits to growth without adequate critical evaluation is a tailor-made, high- cost gamble. More water and high resource input and cost will feed already high and unsustainable population growth driving the Alamo Region into the downsides of sprawling, large urban areas: environmental degradation, higher costs, pollution, congestion, crowding of schools and parks, alienation, crime, and need for more planning, infrastructure, administration, and ever further reaching and risky efforts to control vital resources and waste sinks. That runs up against the growing Texas movement for small government and low regulation and taxation.

Have we learned nothing from the history of water wars and society collapses over water resources? Is San Antonio blind to all the cautionary tales, such as that of Los Angeles and its desertification of Owens Valley and other cases, documented in Cadillac Desert and other sources?

The City recently set a precedent on costly, controversial projects by withholding its $32 million for the streetcar and promising a broad-based committee study, public education, and a vote on the project. The Vista Ridge deal, at more than 100 times that cost, and with many glossed-over downsides, needs the “pause button.”

by Margaret Day, Executive Committee Chair

Press Conference Statement on Request for a Moratorium on SAWS Utility Service Agreements
July 26, 2014

On July 21, members of the Alamo Sierra Club joined forces with the Greater Edwards Aquifer Alliance and other partners at a press conference in support of GEAA’s call for the San Antonio Water System to adopt a moratorium on the utility service agreements for service to any new developments that would threaten the quality and quantity of water from San Antonio’s aquifer. The Vista Ridge project or other massive acquisitions of water should not even be considered until an effective and enforceable set of regulations and restrictions to protect all parts of the aquifer system is put in place.

We are not at all convinced that the extremely expensive Vista Verde project is necessary. As recently as last January, SAWS staff determined that, with the addition of the desalination plant, the City would have adequate and flexible sources of supply. What accounts for the turnabout?

The Sierra Club believes that the best interests of the people of San Antonio will be served by dramatically increasing the protection of the Edwards aquifer and by stepping up water conservation measures among all residents and businesses, alike.

by Meredith McGuire, Conservation Committee Co-Chair

Raising the Cap on Edwards Pumping Solves Nothing
Ken Kramer, Director, Lone Star Chapter, Sierra Club

Management of the Edwards Aquifer has been a complex and contentious issue for years.  Most of us who are veterans of the “water wars” of the early 1990s still have scars from the battles in court and in the Texas Legislature that were fought over aquifer pumping, springflows, endangered and threatened species, and base flows for the Guadalupe River.

In retrospect a number of good things happened as a result of the turmoil of those years.  The litigation by the Sierra Club over concerns about the impacts of aquifer pumping on Comal and San Marcos Springs, important habitat for several endangered and threatened species, served as a “wake-up call” for the Edwards region.

The San Antonio Water System redoubled its conservation efforts, and San Antonio is now recognized as a leader in water conservation among the state’s major cities.  Agricultural producers in the western part of the region began moving toward more efficient irrigation practices.  The Edwards Aquifer Authority (EAA) was created and began implementing a permitting system for regulating water withdrawals from the aquifer.  Some Edwards pumpers diversified their sources of water.

All has not been perfect, of course, but conservation, supplemental water supplies, and management practices – along with some well-timed rainfall – have combined to avoid a major crisis with the aquifer in recent years as all of us continue to grapple with how best to assure protection of the aquifer and maintenance of springflows over the long term.

There has remained, of course, a smoldering issue that results from an inconsistency in the law that created the EAA.  That law, Senate Bill 1477, called for a cap on pumping from the Aquifer at 450,000 acre-feet a year – ratcheted down to 400,000 acre-feet a year by the end of 2007– but it set up criteria for the EAA to issue aquifer pumping permits that could result in as much as 549,000 acre-feet of water withdrawals from the aquifer each year.  That inconsistency complicates the other requirement in the law that EAA prepare and implement a plan to provide continuous minimum springflows to preserve endangered species habitats by 2012.  Now that the permitting process is virtually complete and the deadline for reaching the 400,000 acre-foot cap is less than a year away, this inconsistency must be addressed.

SB 1477 does authorize EAA to take actions to deal with this inconsistency, including a proportionate reduction of all permits in order to meet the cap on pumping and/or acquisition and retirement of specific pumping rights (which would require compensation).  The EAA is also authorized to raise the cap on pumping but only after a determination by its Board that “additional supplies are available from the aquifer, and only after “consultation with appropriate state and federal agencies.”

Now, however, the EAA – with the support of SAWS and many San Antonio officials – has apparently decided to pursue legislation in this session of the Texas Legislature to raise the pumping cap to the permitted amount of 549,000 acre-feet per year without any finding that doing so is scientifically valid.  Indeed the fact that the EAA Board is seeking this legislative “fix” rather than taking such action in the manner authorized in its enabling law is a tacit admission that such a cap increase is not scientifically justified.

The EAA has dismissed the alternatives to raising the cap – apparently on the assumption that proportional reduction of permits across-the-board is too politically volatile and that acquisition of specific permits would be too costly.  In truth, however, EAA has produced no in-depth analysis of these two alternatives to allow the public to have a frank and open discussion on these options.

That’s unfortunate, because raising the cap on Edwards pumping – in the absence of any scientific justification that it can be done without harming springflows – solves nothing.

Indeed raising the cap poses many potential problems – most prominent among them the prospect that the Edwards region is more likely to be put into a critical management period quicker and more often if actual pumping increases to 549,000 acre-feet per year on a regular basis.  That higher level of pumping will take away almost any margin of safety that otherwise might allow the aquifer to “weather” short periods of drought without the EAA having to impose stringent critical period management reductions. 

Moreover, springflows are likely to be reduced on an ongoing basis by an increase in this magnitude of pumping.  That has serious implications for maintaining robust habitats for endangered and threatened species, instream flows in the Guadalupe River for downstream interests, and freshwater inflows to the San Antonio Bay system.

Perhaps the biggest negative of the Legislature raising the cap without scientific justification, however, is that it would reflect a return to the “us” versus “them” approach to the Edwards that so many people have been trying to escape.  It pits pumpers from the Edwards against almost everyone else – the communities at the springs, the downstream interests, environmental groups, and others – and it puts the interests of those pumpers above the interests of everyone else. 

There was a time for fighting over the Edwards.  What is needed now, however, is progress toward a scientifically-based management system for the Edwards that will balance all the competing interests for water from the aquifer – one that is the result of an active and open dialogue among those interests.  Some possibilities in that regard are emerging, but a rush for a legislatively imposed increase in the Edwards pumping cap at this time will undermine or torpedo those possibilities and may well throw us all back into a battle that no one really wants to fight again.  It’s time to move forward, not backward.

AGUA Revision of San Antonio’s Water Quality Ordinance
(Chapter 34 of the Unified Development Code)

AGUA’s revision of San Antonio’s Water Quality Ordinance increases protection of water quality by eliminating the loopholes in the current ordinance.

AGUA’s major recommendations are:

Uniform 15% impervious cover limit
The current water quality ordinances allow from 30% to 80% impervious cover inside city limits while requiring across the board restrictions of 15% in the City’s Extraterritorial Jurisdiction (ETJ). Uniform standards will provide more rational management of growth on the Edwards Recharge Zone.

2 Maintains the natural beauty of the Texas Hill Country within Bexar County, as well as providing a proven solution to mitigating pollution of the Edwards Aquifer.

3 Reduces the need for building, monitoring and maintaining expensive engineered pollution abatement structures on all projects.

4 Uniform restrictions eliminate the practice of increasing allowed impervious cover at transportation nodes up to 80%. This practice of allowing dramatic increases in impervious cover as areas are developed out, which has presented a moving target for efforts to foster sustainable development of the aquifer recharge zone, will be eliminated under AGUA recommendations.

1 Withdraws objections to requests for commercial rezoning, which currently allows for increases of impervious cover from 30% limits for residential zoning to 65% for commercial. This would foster more flexibility in allowing mixed-use development and low impact businesses where they are needed and appropriate.

Ordinance will apply to all sensitive portions of the aquifer

2 Will apply to the Recharge Zone, Transition Zone, and Contributing Zone (within five miles of the Recharge Zone). The current ordinance applies only to the Recharge Zone.

Transfer of development rights

3 Permits flexibility for new developments by allowing increase in impervious cover (up to 30%) with purchase of land or development rights on the Edwards Recharge Zone within prescribed areas. This section will also give the City a planning tool, enabling us to work with land-owners and developers to acquire land for liner parks, watershed protection, open space and public recreational areas.

Hazardous materials rules

4 Requires safeguards for storage of hazardous materials and prohibits storage of more than 600 gallons of hazardous materials.

TCEQ Water Pollution Abatement Plan required

5 City will not consider plans for projects until TCEQ has approved the Water Pollution Abatement Plan.

Non-degradation standard for developments with more than 15% impervious cover

Requires monitoring of discharges for likely pollutants such as metals, pesticides, and petroleum products. Prohibits any increases in contaminant concentrations or loads.