Tuesday evening I attended the Texas Commission on Water Quality (TCEQ) public hearing in Bulverde regarding a developer's application to build four houses per acre, many hundreds of new homes, in the Honey Creek drainage basin and be able to dump 500,000 of treated sewage into Honey Creek, effluent which will at times of high water make its way into the pristine environment of Texas' longest cave. Comments were made by several Texas cavers, including Joe Ransau, Kurt Menking, Linda Palit, Sandy Mosier, Allan Cobb, Andy Glusenkamp, and me. To me, the most moving comment made was that by the cave's owner, and a good friend to our caving community, Joyce Moore. Here it is in its entirety.
Bill Steele speleoste...@aol.com Honey Creek Discharge Permit Comments from Honey Creek Spring Ranch by Joyce Moore My name is Joyce Gass Moore. I am a 5th-generation Texas, and a 5th-generation co-owner of Honey Creek Spring Ranch. Our ranch is located in far western Comal County, and downstream of a proposed Silesia properties development known as Honey Creek Ranch. And so I speak to you today not only as an affected landowner, but as a very concerned citizen. When my son and nephew take over the management of Honey Creek Spring Ranch, it will represent 6 generations of continuous family ownership and a legacy of stewardship dating back to 1846 when my ancestors first set foot on Texas soil. As German-immigrants, my family was one of only a few who homesteaded western Comal County—3 of whom (all neighbors) applied for land deeds on the same day in 1871. Because the waters of Honey Creek were so important to the settlement of Comal County, our entire ranch was recognized as a State Historic Site by the Texas Historical Commission; and in 2018 was Listed in the National Register of Historic Places by the U.S. Department of the Interior National Park Service. My ancestors knew hardship and fought to protect their land and Honey Creek. They carved the ranch out of cedar and live oak covered hills, suffered thru drought, disease, and bank failures, and sacrificed everything they had to nurture, protect, and improve the land they loved. And now—150 years later, once again we are threatened by those who seek to cash in on the land in order to capitalize on its value. Despite what they may tell you, these folks do not hold the best interest of the land or its natural resources at heart. This is very evident in the description of the development being planned. My ancestors would be so deeply disappointed in what western Comal County has become, and in the landowners, who are allowing this to happen. The Texas Hill Country is known for its aesthetic beauty—people have been drawn to this area for generations—drawn to its crystal-clear streams and scenic vistas. Unfortunately, all this beauty rests atop a particularly fragile ecosystem—a calcareous limestone substrate known as *karst*. Although not a geologist or a hydrologist, I do understand how infiltration works—how water moves thru a karst system. Surface recharge features (cracks, fissures, pits, sumps) are all designed to move water quickly into subterranean acquifers (the Edwards, the Trinity, and Cow Creek are all examples). These aquifers provide the drinking water for millions of people. Springs flowing from these same aquifers provide critical habitat to a unique group of plant and animal species—many of which are found only in the most protected streams and riparian areas of Central Texas. Until this proposed development and wastewater discharge became a possibility, Honey Creek was one of the most protected aquatic systems in the Hill Country. The number of these pristine riparian systems are shrinking rapidly—most of it due to rampant and unregulated development over the recharge area, and the failure of an already-broken system intended to regulate the disposal of wastewater. I think it very ironic that the name chosen for the area by my ancestors (Honey Creek) is the same name chosen by newcomers to become their sales pitch. It is the same aquatic system that will be destroyed if this Honey Creek Ranch permit is approved. Treated effluent discharged into a tributary of Honey Creek will absolutely, negatively impact water quality--primarily through significant increases of Nitrogen and Phosphate levels. These nutrients will encourage the growth of algae and will degrade the recreational and aesthetic value of Honey Creek. Decaying mats of algae will impact Dissolved Oxygen levels and will almost certainly have a devastating effect on aquatic life. The introduction of Pharmaceuticals and Personal Care Products contained in the effluent will eventually enter Honey Creek and then will become a dramatic example of how a once un-impaired aquatic system with exceptional levels of aquatic life use, was degraded due to wastewater and high-density residential development. It will become yet another Poster Child for Poor Management—all in the Name of Progress! And if 500,000 gallons of treated wastewater discharge were not a large enough problem, the non-point source pollution reaching the creek during storm events and leaching into the aquifer will be an even greater problem. Herbicides, pesticides, and fertilizers used on turfgrass lawns, and oil/fluids leaking from thousands of additional cars will wreak havoc on our groundwater. Because of the immense footprint of this development, open ground will be significantly diminished; stormwater runoff will increase from the many impervious surfaces (roads, driveways, and rooftops). As a result, downstream flooding of Honey Creek will increase in both rate and severity, greatly increasing soil erosion along the streambed, and resulting in significantly diminished water quality. The pristine Honey Creek as I know it, as my family knows it, will be but a fleeting memory. This includes not only the stream itself, but also a 20+ mile network of subterranean, water-filled karst passage known as Honey Creek Cave. The cave and spring system form yet another unique ecosystem which has been studied and documented on our ranch for over 40 years by trained experts (many of whom are in this room tonight). It is inhabited by unique aquatic species, several of which are state threatened, and at least one which may possibly receive federal protection, and all of which are considered Species of Greatest Conservation Need. Without question, ALL of these species (which require clean, clear water to survive) will be negatively impacted, and most likely extirpated. Who will monitor the effluent discharge with regard to its environmental impacts? And when violations occur, will the violators be held accountable? The irony is that *when* the sewage treatment plant fails (because ALL eventually fail), the damage suffered by the ecosystem will already have taken its toll. Trespass will now also become a major problem to those of us who live downstream. Ambitious adventurers will trek illegally from their suburban lots seeking open space. They will venture onto adjoining properties such as the state-owned Honey Creek State Natural Area and beyond. What assurances do neighboring landowners have that measures will be taken to prevent trespass and vandalism, and who will pay for it when it happens? Who will be held accountable? As a downstream property owner; as a directly-impacted landowner with standing, I respectfully request to file a contested case hearing in this matter. And I would ask the members of TCEQ (those present here tonight, and those who will decide the eventual fate of Honey Creek), to explain how such a permit can even be considered for approval? Unfortunately, God is not creating any more Honey Creek’s, and we are destroying these special places at a rapid pace. I urge TCEQ to do the right thing instead of rubber-stamping this project as your agency has a history of doing. And if it is approved, I hope that each of you can live with your decision, as I and Honey Creek will be forced to do.
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