Mr. John Burke, Chairman Lower Colorado Regional Water Planning Group 496 Shiloh Road Bastrop, Texas 78602

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1 September 15, 2015 Mr. John Burke, Chairman Lower Colorado Regional Water Planning Group 496 Shiloh Road Bastrop, Texas Re: Review of the 2016 Region K Initially Prepared Plan Dear Mr. Burke, Thank you for the opportunity to review and provide comments on the Region K Initially Prepared Plan (IPP). The Region K Water Planning Group is to be commended for the effort that has gone into the development of the 2016 IPP. We appreciate the group s dedication to meeting the region s water needs for decades to come and attention to sustainable water management strategies such as water conservation and drought management. Planning for and appropriately managing water resources is everyone s concern and we acknowledge the time, energy, and expertise that have gone into the development of this IPP. We offer the following comments on the IPP: Water Management Strategies are in Excess of Needs (Overplanning) It is the Sierra Club and National Wildlife Federation s position that water management strategies included in the state s 16 regional water plans should closely align with the needs or water shortages identified through the regional water planning process. Region K has recommended water management strategies far in excess of the needs identified in the IPP. A review of recommended water management strategies (WMS) compared to projected needs reveals that recommended WMS are almost double what the needs or projected water shortages are by the year We acknowledge that there are caveats to these numbers. The planning group should examine this issue, identify specifically where the overplanning is occurring and determine which strategies are 1

2 most appropriate to meet the stated needs. We recommend that Region K recommend a suite of WMS that are in line with the actual needs. Total Region K WUG Needs (afy) Total Recommended Region K WMS (afy) Region K Needs Compared to Recommended WMS in 2016 IPP , , , , , , , , , , , ,580 Recommending water management strategies in excess of needs leads to inflated cost estimates and ties up supplies that may be needed elsewhere. In addition, these excess WMS may have substantial environmental, social and economic consequences if implemented. Planning to use more water from aquifers and rivers than is needed to meet human water supply needs is potentially detrimental to the region s ecosystems and makes the planning process more like a list compilation exercise than a true planning exercise. The regional water planning process is adaptable. There are several mechanisms available to water providers to ensure flexibility in water supply approaches. They include a five- year planning cycle to address new information, a straightforward amendment process to quickly deal with changed or emergency conditions, and a mechanism to identify potential water projects as alternate rather than recommended strategies. Region K should use these tools to create a plan that more accurately reflects the water management strategies that are truly needed to meet future water demands. In future planning cycles, we recommend that the planning group have a discussion about how to approach this issue and develop a timeline that allows the consultants and planning group members sufficient time to deliberate whether the inclusion of each WMS is appropriate. This includes evaluating impacts of WMS, including whether the strategies are consistent with the long- term protection of the state s water resources, agricultural resources and natural resources per 31 TAC (b)(c). Water Conservation The Sierra Club and National Wildlife Federation appreciate Region K s careful consideration of water conservation as a water management strategy. However, the recommendation should be stronger. 2

3 As shown in the table below, the 2016 IPP recommends Water User Groups (WUG) apply water conservation as a WMS to reduce their GPCD by 10% per decade for entities with a 200+ GPCD and recommends a 5% reduction in GPCD per decade for entities with a GPCD greater than 140. Region K 2016 IPP Water Conservation Recommendations % reduction per year % reduction per decade >200 GPCD 1% 10% >140 GPCD.5% 5% However, as you can see from the table below, the adopted 2012 Region K plan had a stronger water conservation recommendation. The recommendation from the previous plan is in line with state recommendations that all water users with a GPCD above 140 should reduce water use by at least 1% per year until they reach 140 GPCD. Region K Adopted 2012 Regional Water Plan Water Conservation Recommendations % reduction per year % reduction per decade All WUGs with GPCD above 140 1% 10% WUGs with a need and GPCD % 2.5% With a growing population and intense droughts putting pressure on our water supplies we need to do more on conservation, not less. Water conservation is a cost effective and environmentally friendly way to stretch existing water supplies to meet growing demands. We recommend that Region K consider adopting water conservation recommendations consistent with recommendations from the last planning cycle. It is important to note that the savings do not have to stop once 140 GPCD is reached. Cities such as San Antonio and Austin have reduced their water use below 140 GPCD and are still working to achieve additional savings. Please consider the success of the existing programs and the ability to maximize water savings through advanced conservation strategies. Drought Management The Region K IPP includes a robust recommendation to employ drought management as a water management strategy. The Sierra Club and National Wildlife Federation support this recommendation and commend the water planning group on including this proactive water supply strategy. Central Texans have shown that they are capable of responding to dry conditions by reducing their water use in a big way. This protects and significantly prolongs our water supply during 3

4 drought, which allows communities to avoid costly water supply projects that may only occasionally be needed. Inclusion of this strategy acknowledges previous success and helps communities take this strategy seriously. We support the planning group s recommendation that water suppliers consider coordinating drought stage information among users of the same source of water. We believe this will enhance public knowledge of and improve participation, which leads to successful implementation of drought measures. We also support the planning group s recommendation that water suppliers begin education efforts prior to reaching drought stage levels. Environmental Impacts of WMS The Sierra Club and National Wildlife Federation are concerned that the environmental impacts of some of the WMS in the Region K plan are understated and that the Region K s impact analysis masks some of the potential environmental impacts of water management strategies. We acknowledge that such an impacts evaluation can be complicated. Using WAM Run3 as the starting point for evaluations masks many real world impacts. However, many of the proposed strategies WILL have an impact on the quantity and timing of environmental flows as compared to current conditions. Those impacts should be acknowledged in a quantified manner where possible. Shifting water use from agriculture to municipal and steam electric, increased reliance on direct and indirect reuse, full use of water rights and new downstream surface water storage have the potential to significantly alter the quantity and timing of instream flows in the Colorado River and freshwater inflows to Matagorda Bay, thus impacting fish and wildlife populations. Region K members should do all they can to understand and address this issue. The IPP states that several of the WMS have the potential to reduce instream flows. We are concerned about the cumulative impacts of these strategies since reduced instream flows are listed as a potential impact for numerous strategies. The RWPG should consider examining the cumulative impacts of WMS and at least provide some kind of analysis of the potential impacts in Chapter 5. Unique Stream Segments The Region K IPP does not include any recommendations for designation of ecologically unique stream segments. Work has previously been done to identify these segments and provide relevant information per 31 TAC This information has historically been included in the Region K plan and it is our understanding that these were inadvertently left out and will be added back into the final plan. Please ensure that information on ecologically unique stream segments is added back into the Region K plan prior to final submittal. 4

5 Creating a Regional Water Plan that Includes all Needs The failure of regional water planning groups to address environmental water needs is an issue in all 16 regional water planning groups and in the planning approach put forth by the Texas Water Development Board. While it is understood that environmental water needs will not be included as a water need in the 2016 IPP, Region K should consider including this important user group in the development of the 2021 regional water plan. To be comprehensive, a water plan must include all water needs. We appreciate the policy statements in Chapter 8 that support this concept. The Region K plan should do what it can to ensure that water is available to meet the needs of fish and wildlife. If the Colorado River, its creeks and tributaries and Matagorda Bay are not healthy and productive, this region will not be healthy and productive. Thank you for the opportunity to submit comments on the Region K IPP. We commend the planning group for their thoughtful consideration of the water supply challenges and solutions in the region. Much of the success of Region K is due to the ability of the members to work together as a group and in subcommittees to understand and vet the issues under consideration as part of the planning process. Thank you for your consideration of these comments. Please feel free to contact me if you have any questions. Sincerely, Jennifer Walker Water Resources Coordinator Sierra Club, Lone Star Chapter jennifer.walker@sierraclub.org Myron Hess Manager, Texas Water Program/Counsel National Wildlife Federation mhess@nwf.org Cc: Jaime Burke, AECOM Stacy Pandey, LCRA 5