Correction: Make that the Texas Commission on Environmental Quality (TCEQ).
> On Aug 23, 2019, at 5:01 PM, Bill Steele <cwilliamste...@gmail.com> wrote: > > 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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