Rapid growth in Comal County could impact the quality of Canyon Lake’s water supply if new wastewater treatment plants are not properly permitted.
Annalisa Peace of the Greater Edwards Aquifer Alliance (GEAA) says subdivisions being developed in cities and unincorporated areas of Comal County allow for wastewater treatment plants, as well as individual septic systems, in close proximity to the Edwards Aquifer Recharge Zone.
Speaking at Tye Preston Memorial Library as a guest of League of Women Voters-Comal Area on Tuesday, Nov. 16, Peace explained the State of Texas permits wastewater discharged from these new plants to flow directly into area creeks and dry creek beds that feed the Edward Aquifer and its surrounding recharge zones.
“As we all know, the growth in Comal County has just gone through the roof, and we need to see what the impact is on lives, on water, and on land,” says the League’s Community President Roxanna Deane. “One of the issues that’s come up is wastewater treatment facilities now part of life here.”
What’s at stake?
At issue are the types of permits and the quality of plants built by developers in the Edwards Aquifer area, designated as the state aquifer most-vulnerable to pollution by the Texas Commission on Environmental Quality (TCEQ).
The aquifer is the primary source of drinking water for millions of Texans.
What keeps experts like Peace up at night is the possibility that wastewater leaks could result in high concentrations of bacteria that might sicken thousands of people with intestinal diseases like giardia or cryptosporidium.
“We’ve been fighting permits for direct discharge on a case-by-case basis,” Peace says. “We have contested so many of them and we’ve won several and lost some.”
GEAA partnered with Friends of Canyon Lake to protest renewals for Canyon Lake-area wastewater infrastructure that’s not in good condition.
Tracking future problems
GEAA is currently mapping locations of storm-water and wastewater permits in Comal County in order to track possible future problems with water quality in Edwards and Trinity aquifers.
There are five to six houses per acre in the Comal County area’s high-density subdivisions, which GEAA argues is inappropriate for maintaining water quality in recharge zones.
The minimum lot size/spacing requirements for properties in Comal County that have on-site sewage facilities and are not over the Edwards Aquifer Recharge Zone (EARF) is 1.0 acre for public water and 5.0 acres for private water. State law for properties over EARZ with OSSFs is 1.0 acre.
Aquifer-related requirements call for minimum property size of 5.0 acres with private water as more protective of private wells, which could be subject to contamination from sewage leaks.
Protecting a unique aquifer
“The Edwards Aquifer is an irreplaceable resource that has been subjected to significant urban growth and development, resulting in loss of recharge due to impervious cover replacing native landscape cover,” Peace says.
“The Edwards Aquifer is a karst aquifer, a type of aquifer that is especially susceptible to contamination because pollutants from runoff, leaks, spills, lawn treatments and other sources can reach the water table within minutes and travel quickly through the aquifer with effectively no filtration,” she says.
GEAA collaborates with Friends of Canyon Lake in Comal County and other member groups throughout the Edwards region to oppose renewal of Texas Pollutant Discharge Elimination System (TPDES) permits that regulate discharges of pollutants to Texas surface waters.
Texas legislators recently passed HB 1865/SB 709 that make it difficult for individual citizens to contest permits for sewage infrastructure. Comal County lacks the authority to regulate land issues.
Most developers obtain Texas Land Application Permits (TLAP) which require treated effluent to be disposed of on effluent application sites, also referred to as “beneficial reuse.”
As subdivisions expand, developers frequently request amendments to TLAP to TPDES to allow for development of land used for land-application discharge.
“Many of these permits are within close proximity to one another, and many are located within the various vulnerable regions of the aquifer,” Peace says.
Permit locations listed on TCEQ’s website also are vague, she says.
“This lack of information poses many problems. Currently, TCEQ considers the potential cumulative impacts from all permitted or proposed storm-water permits, but without accurate information in their database, it is unclear how this is done.”
Active or pending TPDES permits into Cibolo Creek Watershed in Comal County include:
- Johnson Ranch MUD – 350,000 gallons/day into unnamed tributary of Cibolo Creek.
- 4S Ranch Subdivision – 480,000 gallons/day into unnamed tributary of Lewis Creek.
- Cibolo Valley Waste Water Treatment Plant – 500,000 gallons/day into Cibolo Creek.
“Combined permits equal direct discharge of 1.33 million gallons/day of sewage effluent that will flow into Cibolo Creek, a major recharge feature of the Edwards Aquifer,” Peace says.
Bracken Ranch Subdivision could discharge 500,000 gallons/day of sewage into Lewis Creek.
Other TLAP permits in Comal County that could be amended to TPDES are for Singing Hills, Vintage Oaks, River Crossing and other developments.
How to get involved
Citizens who want to learn more about water supply from Edwards Aquifer can visit AquiferAlliance.org and sign up for legislative alerts.
Additional information about studies and environmental impacts also are available on the group’s site.
The meeting was open to the public. Also in attendance at Wednesday’s presentation were Scott Haag, Comal County Commissioner, Pct. 2; Jen Crownover, Comal County Commissioner, Pct. 4; Comal County Engineer Tom Hornseth; Yvonne Chapman, Bulverde City Council; Mary Lou Jenkins, member of Bulverde Zoning Board of Adjustments; and Diane Wassenich, public representative serving on Region L Water Planning Group.
Tom Hodge, vice president and general manager of Canyon Lake Water Service Co. and a member of Canyon Regional Water Authority, also spoke at the event, defending the quality of water from water-treatment plants.
(Editor’s Note: High-resolution, panoramic images of Edwards Aquifer are not available. MyCanyonLake.com checked with GEAA and were told the Trinity Aquifer — which also is a karst aquifier — is the same in appearance as the Edwards Aquifer.)