Saturday, February 19, 2011
The groundwater district's 5-member board will consider the application at its regularly scheduled monthly meeting on Monday, Feb. 21, 1 pm, at Dripping Springs City Hall, 511 Mercer Street
Note: Below is information in the application filed by Winton Porterfield with the Hays Trinity Groundwater Conservation District (HTGCD) for a permit for Wimberley Springs Partners to become a Public Water Supplier (PWS). The public rarely gets a chance to review detailed communications between the District and permit applicants. The Q&A, between Mr. Porterfield and the District's GM, Rick Broun, is informative and very timely. Decide for yourself. Is groundwater best used for the build-out of a dense development at Wimberley Springs and irrigation of golf courses? Is anyone checking if the irrigated effluent contains harmful bacterial and chemical residue?
There's a good chance the permit will be approved. If it is, it will the first new large volume groundwater production permit allowed by the Board since last May's election when three new board members were seated.
Wimberley Springs Partners (WSP) states below that they have an agreement until 2037 with Aqua Texas to accept up to 600,000 gallons of effluent per day on the two golf courses. The golf courses are really just a matrix to accept sewage. (As golf courses, they reportedly are losing hundreds of thousands of dollars annually for WSP.)
In the answer to question 8, WSP states, "Our goal is to get 80% effluent irrigation, but the mechanical systems to irrigate effluent are more expensive than [for] groundwater, so we want the flexibility to sell or lease groundwater rights [to others] in order to fund improvements to the effluent distribution system."
Some believe WSP's plan is to get a permit in their name, but then lease rights to others (probably Aqua Texas, who is not popular at the moment with TCEQ) to pump much of the water they persuade HTGCD to permit them (WSP). It's questionable whether this practice is legal.
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Click on this link to download a copy of the meeting/public hearing agenda (Feb. 21 on the calendar) and directions to Dripping Springs City Hall.
Subject: Wimberley Springs Partners Permit
Board and Staff,
On Thursday, February 10, 2011 I met with Wimberley Springs Partners (WSP) / Winton Porterfield at the District office. We met for over three hours and I have been in communication via email and telephone concerning his application to the District. There were some follow-up action items that WSP has now provided the District, see attachments.
The following are the questions, answers and notes regarding his permit application. Included within the following are geological and science-based points.
1) Question: WSP has 6 wells listed in its application and 6 wells on your quarterly reporting. We'd like to know all 6 well names and how much they produce.
Answer: The only well producing is the Doolittle well, located within the City of Woodcreek. The other 5 wells are: Bull Frog, Maintenance 1, Maintenance 2, Park Well and Section 25 well.
Production History of Doolittle: 2006: 36,806,400 gallons or 112.95 AF (acre-feet) 2007: 30,326,400 gallons or 93.06 AF 2008: 38,620,800 gallons or 118.52 AF 2009: 24,962,400 gallons or 76.60 AF 2010: 15,038,900 gallons or 46.15 AF Total: 145,754,900 gallons or 447.3 AF Average over 5 Years: 89.46 AF
Note: WSP has owned these 6 wells since April 2001, all drilled prior to the formation of the HTGCD (District) / 1973,1976 & 1998, see maps. 5 wells were tested for pumping capacity in early 2001. The wells are capable of groundwater production from the Middle Trinity, Cow Creek formation. Test production ranged from 33-425 gpm. 4 wells were completed "open-hole". The Park well (908) was packed with gravel from 183 to 284 feet (T.D.). The Bull frog well (902) was classified as "abandoned". Those wells not in use have been capped. There has been some minor pumping from the other 5 wells, but only when WSP lowers a pump to check if wells are capable of production.
2) Question: Which wells does WSP use to produce for the current golf course and which wells will be used for the rebuild golf course.
Answer: Doolittle well will continue to be used for WSP's current use. For our rebuild golf course, WSP will use Section 25 well and Park Well.
Note: WSP wells are in close proximity to Aqua Texas wells, Wimberley WSC public supply wells and Jacob's Well. According to WSP, Aqua Texas acknowledges and approves of WSP's permit to produce in such close proximity even though WSP will be within Aqua Texas' CCN.
The District has evidence that pumping from Aqua Texas wells 21 and 23 (Aquifer Pump Test) impacts Jacob's Well by reducing flow. The District has no information on the impact of increased WSP pumping on the public water supply wells or on Jacob's Well. The District has a geophysical log from one well, Maintenance 2. WSP has also allowed the District to place a transducer in the Maintenance 2 well for monitoring purposes.
Normal faults from the Tom Creek Fault System cut the property from southwest to northeast. A geologic cross-section constructed from Aqua Texas 23 to the South Golf Course well (703) indicates a drop of 270 feet to the southeast between the two wells. The water levels between the two wells however, are within 5 feet. It appears that the fault is not sealing.
3) Question: Will unused wells be plugged?
Answer: Yes. Once the golf course has been planned and designed, unused wells will be plugged. In the mean time, they will be fenced to restrict access and covered.
Note: Wells not in use have been capped.
4) Question: Are there any other wells WSP plan to use and will you drill any new wells.
Answer: Depending on the golf course design, those wells included in our application. WSP doesn't plan to drill any but it's possible if we determine, along with the District, that it is desirable to drill a new well to better locate the pumping and lessen potential impacts.
Note: Domestic wells are not allowed in the subdivision. All new wells will require an Aquifer Test.
5) Question: Does the effluent that WSP uses come from Aqua Texas? If so, is it treated and might it cause concern to the neighbors?
Answer: Yes, the wastewater effluent is treated as per a permit that Aqua Texas has with the TCEQ. The disposal area included in that permit includes both golf courses.
Answer: Wastewater effluent has been used for golf course irrigation on both courses for more than 20 years. Deed restrictions for lots on both courses includes statements about the use of sprayed wastewater effluent, so home owners and potential buyers should be aware of this fact.
6) Question: Does WSP have a contract with a supplier for an amount of effluent each month? If so, how much and how might that change over time?
Answer: Yes, with Aqua Texas, up to 600,000 gallons per day. Currently Aqua produces about 200,000 gallons per day.
Answer: Aqua's contract runs until 2037
7) Question: WSP did file a Drought Contingency Plan (DCP) with the District some time ago, would you like to review the DCP or fill out a new one?
Answer: We can use the original for the purposes of the permit application. I am also willing to use the cutback percentages we had in the draft standstill agreement, as permit conditions.
8) Question: In 2010 WSC pumped 49 AF (15.9 million gallons), please explain the need for 250 AF (81.4 million gallons) per golf course.
Answer: The amount we pump is dependent upon rainfall and when we get that rainfall. Rainfall for 2010 was 40 inches, well above the 32 inch annual rainfall average for the region. Our average annual groundwater usage since 2002 for the one golf course has been 114 acre feet. Add a second golf course (with turf that will need to be established) and 250 is a conservative number for the maintenance of two golf course until more effluent is available. Our goal is to get 80% effluent irrigation but the mechanical systems to irrigate effluent are more expensive than groundwater so we want the flexibility to sell or lease groundwater rights in order to fund improvements to the effluent distribution system.
Note from the District GM: WSP permit application is requesting 997 AF (324.8 million gallons). There are two areas requiring groundwater: Woodcreek and Woodcreek North. This is not my recommendation, but rather the break-down of WSP's permit request. 125 AF/Yr. for Woodcreek, 125 AF/Yr. for Woodcreek North, and 250 AF/Yr. to re-establish golf course vegetation. Once the new golf course has been established, that 250 AF/Yr goes away. Depending on when WSP requires the additional 250 AF for re-establishing vegetation, the permit should be flexible. An example for a 3-Year permit: First Year: 250 AF Second Year: 500 AF Third Year: 250 AF
General Notes: As WSP is applying with the District as an Irrigation and as a Public Water Supplier (PWS), connection fees are in effect and will constitute a $300 per household connection fee as stated within District Rule 12.1 B. Neither the District permit nor the District Rules state the selling or leasing of groundwater, but perhaps Greg Ellis (HTGCD attorney) can confirm.
Quarterly Reporting, District Rules including compliance, Loss and fines, Water Conservation and Drought Contingency Plans, the entire permit shall be acknowledged by WSP and followed. WSP will follow all guidelines as stated by the TCEQ and their PWS policies. WSP and Aqua Texas acknowledge that WSP will be pumping within the CCN of Aqua Texas. Reviewing the District Rules, we can't force WSP to comply with an Aquifer Test ($20,000 -$30,000) as their wells are not new.
Administrative Check List for a pre-existing well permit: 1) Operating Permit Application: Completed 2) Proof of published notice: Completed 3) Proof of mailed notice: Completed 4) A Water Conservation Plan: Completed 5) A Drought Contingency Plan: Completed 6) A location Map: Completed 7) Evidence of annual production quantities, unaccounted for water and water levels in all production and monitoring wells over the past 5 years: Completed
Posted by RoundUp Editor at 1:35 PM