SAWS Bed and Banks Application

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1 SAWS Bed and Banks Application Gregg Eckhardt Senior Analyst, Production and Treatment Operations AWWA/WEAT Summer Seminar

2 Page 2

3 Resource Management For: SAWS recycled water system Provision of water to CPS Energy Downstream flows Page 3

4 WRC Daily Production 1991 to million gallons per day Total WRC Production 0 Jan-91 Jan-93 Jan-95 Jan-97 Jan-99 Jan-01 Jan-03 Jan-05 Jan-07 Jan-09 Jan-11 Jan-13 Page 4

5 Typical WRC Diurnal Discharge Curve GPM 120, ,000 CFS ,000 60,000 40,000 20, Hour Page 5

6 SAWS Recycled Water System Page 6

7 Uses of Recycled Water landscaping golf courses cooling towers industrial processes Page 7

8 CPS Energy Page 8

9 Downstream Flows SAWS recycled water effluents are a critical contribution to the San Antonio River during drought periods October 1: Board of Trustees provided direction on SAWS position toward uses of current and future discharged effluent Conquista Crossing on the San Antonio River near Falls City Page 9

10 Bed and Banks Basics Bed and Banks authorization is permission to use State s watercourses to transport privately owned groundwater so that it may be reused downstream Without an authorization, discharges become the property of the State Page 10

11 1980s Council Direction on Discharges 1988 Regional Water Resources Plan recommended a reuse program: must be managed to maintain a minimum flow in the San Antonio River of 55,000 acre-feet per year as measured at the Falls City gauge. Plan was adopted by City Council ordinance Page 11

12 1980s Council Direction on Discharges City Council ordinance was the basis for recycled water system design capacity: Original Recycled Water Program Balance CPS Energy Downstream estimated needs Recycled water system 40,000 af/yr 55,000 af/yr 35,000 af/yr 130,000 af/yr However there are currently no legal protections to ensure water remains instream Page 12

13 Firm Yield Effluent Allocation acre-feet 140, ,000 consumptive reuse - 25,000 af/yr 100,000 80,000 electrical generation - 50,000 af/yr 60,000 40,000 20,000 environmental flows - 50,000 af/yr 0 Page 13

14 Effluent Discharge Routes Guadalupe River at SH 35 near Tivoli Page 14

15 E-Flows Overview SAWS has actively participated in two legislatively mandated programs to address flows in San Antonio and Guadalupe River basins: Program Texas Instream Flow Program (TIFP) Environmental Flows Program (E-Flows) Legislation Senate Bill 2 (2001) Senate Bill 3 (2007) Key Features Agencies determine flows necessary for a riverine "sound ecological environment Recommendations based on field analysis Stakeholder input is considered All watersheds to determine E-Flow needs for each major basin and bay system Science-based flow recommendations SB 2 flow science to be incorporated into SB 3 process Stakeholders balance environmental and human needs Page 15

16 E-Flows Science Team Decision Diagram USGS Gages Info on Hydrographic Methods Option Decision Data Selected Gages Annual/Median Flow Patterns Seasons Flow Data Other Hydrographic Software Period of Record MBFIT HEFR Overbank and High Pulse Flows IHA Subsistence Flows Water Quality vs. Flow Data Base Flow Designations Monthly Calendar Seasons Custom Seasons Pre Development Post Development Entire Period of Record 7Q2 Summer Custom Median 25/50/75 Divisions Custom Matrix Presentation Select Estuary Flow Matrix Methodology Frequency Based Pre Development Original Entire Period of Record Original Pre Development Original Post Development State Methodology USACOE Information Fluvial HEFR Matrices Frequency Based Post Development Frequency Based POR Overbank & High Flow Pulse Data Biota of Rivers and Estuary Salinity Suitability Analysis Seasonal Hydraulic Condition Geomorphology and Sediment Transport Matrices Modified by Overlays Selected Species Biology Other Relevant Studies Gage Flow Data WAM Palmer Index BBEST Flow Regime Water Quality Temperature and DO vs. Flow Wet/Dry 25/75 Percentiles 303(d) List BBEST Flow Regime Application Historical Attainment Frequencies Page 16

17 Components of a Flow Regime Subsistence Flows Base Flows Pulse Flows Overbank Flows San Antonio River Guadalupe River San Antonio Bay Page 17

18 The Aransas Project v. Shaw, et al Although SB 3 does establish a comprehensive framework for the State of Texas to determine the amount of freshwater inflows that need to remain instream it makes no attempt to ensure that such recommended amounts remain. - Honorable Judge Janis Jack, United States District Court for the Southern District of Texas, Corpus Christi Division National Geographic Magazine, 1937 Page 18

19 SB 3 Stakeholder Work Plan Outlines voluntary strategies to meet instream flow standards Page 19

20 Objectives Support SB 3 stakeholder strategies to ensure healthy rivers, bays, and estuaries Add legal certainty to policy guidance Ensure San Antonio retains ownership and control of all current and future groundwater based discharges Page 20

21 Summary and Other Considerations 50,000 af/yr used solely for instream flow purposes Remainder for any legal purpose (in the future) Carriage losses Protection of water rights issued based on use or availability of effluent Development of "Accounting Plan" Page 21

22 Latest Develoments In Ex Parte lawsuit, GBRA asserts EAA Act prohibits indirect reuse of Edwards water EAA Act prohibits reuse outside of EAA boundaries GBRA must have the right to divert discharges of Edwards-derived wastewater effluent as part of the state-owned run-of-river flow of the Guadalupe river..." TAP ruling Page 22

23 TCEQ Request for Information "Staff believes that TCEQ does not have authority under statute to issue a permit based on this application." Page 23

24 TCEQ Request for Information "...the application does not fall under [the reuse] statute because this statute requires that a permitee divert and reuse groundwater based return flows..." Page 24

25 SAWS Bed and Banks Application Gregg Eckhardt Senior Analyst, Production and Treatment Operations AWWA/WEAT Summer Seminar