Ask a Comal County commissioner why they don’t listen to angry constituents and put the brakes on explosive growth that’s turning beautiful Hill Country land into hellish lunar landscapes with thousands of houses crammed onto the smallest possible lot sizes, and they’ll point fingers at the Texas Legislature.
By law, they can’t override state agencies like the Texas Commission on Environmental Quality (TCEQ), which ultimately approves most of the air-quality and wastewater permit applications it receives for commercial projects and residential developments regardless of their impact on dwindling water supplies.
For years, Pct. 4 Commissioner Jen Crownover has warned constituents the county does not have the “tools in the toolbox” to limit growth. If a developer dots the i’s and crosses the t’s on a plat for a proposed subdivision, commissioners must approve it or face expensive lawsuits from big business.
She’s spent the last several years trying to convince Austin to grant counties some limited land-use authority over development.
“Without water, none of the rest of it will matter anyways, right?” she posted on Facebook.
There may be no getting around the state legislature, but environmental conservation groups say there’s another way to safeguard Comal County’s water systems.
Thursday, commissioners will consider applying for a $25.5 million loan from another state agency, the Texas Water Development Board (TWDB), which provides planning and financial assistance for the development and management of water resources.
The money would be used to preserve critical working lands over recharge zones of the Edwards and Trinity aquifers, significant water sources for Texas Water Company (TWC) and New Braunfels Utilities (NBU), without the use of eminent domain.
“It is hard to put into words just how significant this step is for our county and for our communities,” Comal Conservation, an environmental advocacy group, said in a statement. “… This application is a chance for our county government to take action and work to protect the land, water and wildlife that we care about so much.”
But there’s a catch to that money, made available through the TWDB’s Clean Water State Revolving Fund (SRF).
Nobody’s sure how much it will cost property owners already chafing at high tax rates.
Annalisa Peace with the Greater Edwards Aquifer Alliance said funding for the $30 million project breaks down roughly into a $4.5-million grant that qualifies for loan forgiveness and a $ 25.5-million low-interest loan paid over 30 years.
Pct. 1 County Commissioner Doug Leecock, who formerly served on Comal Conservation’s board, says he’s not comfortable discussing rough estimates of how much the loan might increase taxes, but will meet with the county’s financial team this week to prepare a report on the proposal’s short- and long-term financial considerations.
“Furthermore, it is critical as well that we have a clear understanding of the scope that these funds are meant to be used for, should our application be approved,” he said in an email.
Comal County developed a Parks, Open Space and Natural Area Master Plan (POSNA), which increased the ranking of the county’s project-information form.
TWDB prioritized funding for Comal County, ranking it number two on a list of counties that could benefit environmentally with SRF funds.
“Comal County is launching a Water Quality Protection Lands Program to acquire key properties within critical recharge and watershed zones of the Trinity and Edwards aquifers, as well as local rivers and creeks,” TWDB wrote in its 216-page Clean Water State Revolving Fund State Fiscal Year 2026 Intended Use Plan.
“The initiative aims to safeguard both surface and groundwater by reducing non-point source pollution and preserving natural springflows.”
Lands targeted for purchase will feature:
- Karst formations (the Edwards is a karst aquifer)
- Riparian buffers
- Endangered species habitats
- Potential for impervious cover removal
Acquired lands would be carefully managed with limited low-impact recreation permitted where appropriate. An asset-management plan would guide long-term stewardship of environmental resources.
The county would be tasked with identifying high-priority parcels of land that align with conservation goals. TWDB would review and approve all parcels before funding them as complete acquisitions or conservation easements.
Land and easement costs are expected to double within 10 years and priority parcels may be subdivided or sold soon if not protected.
“Since properties are being developed at breakneck speed, permanent protection of lands that provide ecosystem services (recharging the Edwards and Trinity aquifers and preventing flooding) is something we need to do while we still can,” Peace said.
Ryan Spencer, executive director of Comal Conservation, said projected water demands for the county and region will require innovative solutions that are proactive in nature.
Spencer declined to predict which way the court’s vote will go Thursday, but at least one of the county’s four commissioners, Pct. 2 Commissioner Scott Haag, believes the county’s role in funding park systems should be limited.
“I like open spaces, and I like park spaces, but I don’t want the county to have to fund this,” he said during a 2023 discussion about POSNA.
He encouraged the county to rely on nonprofits and state agencies, such as Texas Parks and Wildlife Department, to fund land acquisitions or large park projects.
Spencer said 1,000 people move into Comal County each month. The county can rely on new taxpayers to pick up a large chunk of the loan repayments.
“We borrow money all the time for libraries and jails,” he said. “Additional debt absorbed by the county will pale in comparison to the benefit the county will receive.”
Preserving the aquifers also means preserving the county’s vibrant tourism business. Visitors to Canyon Lake and the Comal and Guadalupe rivers generate an estimated $1.2 billion in revenue annually.
Nobody visits Comal County to see quarries or subdivisions.
Spencer and Peace urge residents to speak out at Thursday’s meeting or email and call their county commissioners to express their views on the loan application.
Click here for contact information for the county’s four commissioners and County Judge Sherman Krause, who presides over Commissioners Court.
Next Steps
Commissioners will make three decisions Thursday.
The first is to allow Judge Krause to sign a document confirming the county’s intent to apply for the loan.
The second is approving a line-item transfer from one part of the county’s budget to another to pay for an expert to work on the application, which is highly technical and will run between 500-1,200 pages.
The third is a vote authorizing the county to pay the expert’s fee.
Comal County spokesperson Cary Zayas confirmed Judge Krause will not be present in court Thursday, but Leecock said the item will still be considered. The loan application is due by Dec. 4.
Spencer said Thursday’s agenda item was years in the making.
The first step, in 2023, was adopting a POSNA then getting it approved by TWDB. The agency liked the document so much it immediately ranked the county #2 on a prioritized list of projects, statewide.
If the court approves the application Thursday, there will be further back-and-forth between the county and TWDB before it is finalized.
The county should receive funding sometime during the first half of 2026.
Those funds also can be used to apply for other regional conservation grants that aren’t loans.
Water Resources
Understanding the county’s water shortage woes requires a basic understanding of how the Trinity and Edwards aquifers work.
The Edwards is a karst aquifer that replenishes itself quickly after heavy rains while the Trinity is a limestone aquifer that probably never fully recovered from the years-long drought of the 1950s, according to Larry Hull, board president of the Comal Trinity Groundwater Conservation District (CTGCD) in Spring Branch, which regulates the spacing of private water wells and provides rules on well construction standards.
Little is known about the upper, middle and lower levels of the Trinity Aquifer, which is more complex and not as well-studied, making it difficult for experts to calculate how much water it actually holds.
What they do know is that water wells drilled in western Comal County are drying up at alarming rates and the aquifer no longer produces as much water as it once did for TWC, Canyon Lake’s provider.
Comal County is located in the South Central Texas Regional Water Planning Area, which encompasses all or parts of 21 counties that stretch from the south central Texas Hill Country to the coastal plains. The group is tasked with developing a regional water plan every five years based on conditions that the region would face under a recurrence of a historical drought of record.
The results of the regional water plan are included in the state water plan and inform state financial assistance and surface-water right permitting decisions.
The 2026 plan is currently under development and due to TWDB by the end of the month.
Spencer said the 2021 plan dramatically underestimated Comal County’s thirst for water supplies.
“Our region is experiencing a wave of population growth that is unprecedented in our history,” he said. “When you match this with an unrelenting drought, questionable water use (green lawns), and complex/confusing water regulations, you set the stage for water shortages, water rate increases and the loss of environmental flows.”
NBU has access to roughly 50,000 acre-feet of water but currently consumes only 17,000 acre-feet of water. Spencer said it’s done a good job of creating resiliency and its impact fees have created a sizeable fund to develop infrastructure.
Most of NBU’s water comes from Canyon Lake, the Edwards Aquifer, Guadalupe River and the Carrizo-Wilcox Aquifer to the east of Comal County.
Things are a bit more complicated for TWC thanks to the Trinity, one of the most extensive and highly used groundwater resources in Texas.
TWC has access to 18,000 acre-feet of water per year. Currently, 6,000 of its supply comes from Canyon Lake reservoir, 6,000 comes from the Trinity Aquifer, and 6,000 comes from recently purchased KT wells, supplied by the Trinity Aquifer.
In December 2022, County Engineer Tom Hornseth told commissioners he was satisfied with then-CLWSC’s updated water availability report reaffirming the utility’s ability to keep up with rapid growth.
“This allows the county to approve subdivisions that are connecting to these utilities during the next three years, and as these utilities grow and their service areas get larger and their demands get larger we then reevaluate their capability to serve these proposed subdivisions,” he said.
Water supply was expected to be in excess of demand over the next 20 years.
“CLWSC has the experience and resources to meet the projected demand within its service area over the next 20 years.”
But in August 2024, TWC Customer Service Manager Katasa Carson said drought forced the company to extend intake pipes 300 feet further into Canyon Lake at its Triple Peak Facility.
“The current extension of intake pipes at Canyon Lake does not increase our water supply,” said Communications Specialist Khameya Taylor. “That work was done solely to maintain access to our existing allocation — not to draw more water. TWC is not permitted to draw more water from Canyon Lake than what has already been allocated, and we are not doing so.”
In March, the utility temporarily paused new service commitments for nine proposed developments in the county, citing rapid growth and drought. These developments are not moving forward at this time. This does not mean they are “ready to go.”
The developments have a combined total of 4,182 lots. Five of those projects in Precinct 1 totaling 2,334 lots, two projects in Precinct 2 totaling 638 lots and two projects in Precinct 4 totaling 1,210 lots.
“Our foremost responsibility is to ensure that when our customers turn on their faucets, they have access to reliable water,” said TWC President Aundrea Williams. “We understand the importance of supporting community growth and we are investing in the infrastructure needed to make that possible in a responsible and sustainable way.”
The unprecedented move was praised by Comal County Precinct 4 Commissioner Jen Crownover, who represents the north side of Canyon Lake where residents are fighting a permit that would allow Lennar Homes to discharge 600,000 gallons of treated wastewater per day into Canyon Lake for the Broken Cedar Ranch development in the FM 484/FM 306 area.
(TWC does not serve Broken Cedar wastewater.)
Spencer said TWC also deserves credit for developing a conservation committee that supports the development of its Water Availability Plan.
“This is a level of transparency and community engagement that is rare of the industry,” he said. “I love the part about their commitment to producing supplies.”
Spencer said a lot is riding on Thursday’s vote.
“Our region is experiencing a wave of growth that is unprecedented in our history,” he said. “When you match this with an unrelenting drought, questionable water use (green lawns), and complex water regulations, you set the stage for water shortages, water rate increases, and the loss of environmental flows.
“Our communities and the region we live in are defined by the clean, clear and flowing rivers of the Texas Hill Country. Every effort should be made to ensure they are protected to ensure they are protected for our kids and grandkids.
“On Thursday the Comal County Commissioners Court will have an opportunity to take historic action. It isn’t a silver bullet, but with its limited authority, the county can protect thousands of acres of recharge zone, ensure that our children have parks and open space, and signal to state and federal government that Comal County is doing its part to protect the most precious parts of the Texas Hill Country.
“Those of us who call Comal County our home and care deeply about the Guadalupe and Comal rivers pray that they do.”